Comments on ERO 019-6160,…

Comments on ERO 019-6160, Proposed Updates to the Ontario Wetland Evaluation System

The proposed updates are entirely inadequate to meet the stated objectives of streamlining the building of more homes.
There are no suggestions of changes relative to the complexities of building homes while maintaining or improving the wetland contributions for healthy and sustainable life in an era of population growth and climate change. There should be updated methodology for measuring the contribution of wetlands in any proposed developments. There should be expanded provincial expertise in assessing wetlands, including their importance in resilience to ever increasing changes in water flows under climate change. There should be expanded consideration of the scale of wetland, and the interconnectedness of wetlands in evaluation systems. Current standards for provincial significance do not reflect the importance that wetlands have in highly populated areas in which small, interconnected wetlands may be crucial.
The ministry should be expanding its level of expertise and playing a role along with municipalities in planning for improvements in housing along with improvements in wetlands, not simply assuming it necessary to deplete one of life's essentials to expand the amount of shelter available.