1.) There is no need to…

1.) There is no need to degrade wetland protection in the name of providing housing. New housing should not be built on wetlands. It should be built in areas that already have infrastructure and are not prone to flooding.

From your own study, Report of the Ontario Housing Affordability Task Force, February 8, 2022, (page 10) it is clear that there is enough land elsewhere currently available for housing :

"But a shortage of land isn’t the cause of the [housing] problem. Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts."

"Most of the solution must come from densification. Greenbelts and other environmentally sensitive areas must be protected, and farms provide food and food security. Relying too heavily on undeveloped land would whittle away too much of the already small share of land devoted to agriculture."

2.) Wetlands provide ecological services that are crucial to Ontarians and thus should be protected at the highest level.

A 2021 study of water filtration provided by southern Ontario wetlands showed a $4.2 billion/year service rendered. Replacing this service by expanding current wastewater treatment capacity would cost the province $164 billion/year.

Wetlands also mitigate flooding and erosion which is key as we see more extreme weather events.
"By storing water and releasing it slowly, wetlands and deltas are important to Canada’s freshwater availability. Under certain conditions, wetlands can alleviate floods, maintain groundwater levels and streamflow, filter sediments and pollutants, cycle nutrients, and sequester carbon" (Federal, Provincial and Territorial Governments of Canada, 2010.) CCCR Report 2019

3.) There is no need to weaken wetland protection by removing OWES from MNRF oversight. It is troubling that the proposed update removes this passage:
"The local MNR office has a detailed understanding of the natural heritage features and functions of the area, has access to current and historic reports, may be aware of relevant information and reports not readily accessible to others, and has connections with other organizations that gather natural heritage information." (page 7)
Why should this expertise a not be accessed? Many municipal governments lack just such expertise to critically assess best practices for wetland protection/development.

Downloading responsibility of OWES to municipal governments will also remove the ability to see a full picture of wetland protection and health in the province.

4.) Also very troubling in this proposed update is the removal of the term "wetland complex."
Wetland complexes occur where two or more wetlands (termed wetland “units”) separated by a non-wetland area are functionally linked. Functional linkages include wildlife usage (e.g., migration corridors, forage areas), and surface water and groundwater connections. Most wetlands in Ontario are complexes. Ignoring this ecological reality is unwise and short-sighted.

Fragmentation of wetland complexes further allows for potential piecemeal development without an eye to the health of the entire system.

5.) Also questionable is the removal of the term "open file" for the term "complete" on wetland evaluation files.

Currently OWES recognizes wetlands as dynamic systems that can change over time (due to natural succession, changes in hydrology, etc) and thus the wetland evaluation files maintained by MNRF District Offices are considered “open files”. These files can be amended from time to time as new information becomes available.

Labelling a wetland assessment "complete" fundamentally ignores the dynamic and changeable nature of wetlands. A mere snapshot assessment during a single season, month or year does not capture the complexity of an ecosystem but could potentially allow development where it previously would have been disallowed.

The proposed updates to the Ontario Wetland Evaluation are not needed by Ontarians to improve housing. We need wetlands to provide clean water, carbon sinks, areas for recreation and tourism and flood mitigation. Wetlands are not appropriate areas for housing development.