I have reviewed this…

I have reviewed this proposal, and have a number of concerns about the nature of these changes, and their implications for sustainable ecosystem management in Ontario. Firstly- by reducing the MNRF's role in the review of proposed changes to wetland boundaries, you are eliminating any form of oversight to these changes- effectively allowing development to proceed without any check or balance. A consultant being paid by a client to obtain a particular result (eg. approve the boundary adjustment) is not in a fair position to make an unbiased or scientific decision about the actual wetland boundary. Whereas, the role of a non-partisan government agency, is to implement a process without an agenda- and make decisions based on facts, not desired outcome. The elimination of MNRF's role in this system creates a high risk situation for the protection of sensitive, irreplaceable features, and simply doesn't work to meet the objectives of the OWES system. Secondly- why would you evaluate wetlands as individual units, when structurally and functionally, these systems are connected?. By virtue of this connection, any change to a part of these complexes, will have impact and influence on other parts of the connected system. Scoring them individually does not make sense in practical application, OR, to support sustainable development. This change seems to be aimed at purposefully driving the wetland score down, to remain below the significance threshold, much more than "reducing administrative boundaries" or streamlining the review process. Finally-- the willful omission of species at risk (endangered and threatened) doesn't make sense, and again, seems targeted at specifically creating barriers to a wetland to ever be scored as significant. Many of Ontario's SAR species reside in, or adjacent to, wetlands- thus, protection of the wetland also serves as protection of SAR. Failing to acknowledge the value of these systems to protect rare species and communities, does not appear to have any scientific merit, and should be stripped from this proposal.