Hello, Thank you for the…

Hello,

Thank you for the opportunity to comment on the proposed changes to the Ontario Wetland Evaluation System (OWES). I am a resident of Grey County with a young family - we were lucky enough to buy a house this year, but I know so many could not. We are certainly in a housing crisis, and increasing supply is one part of the puzzle for sure, but there is no evidence to suggest that these changes to OWES are needed to increase affordability.

I use the OWES frequently in my professional life as a planner. The OWES has been an important tool in identifying significant wetland features throughout the Province of Ontario. The system could certainly use some work, I recognize that aspects may be outdated as it is from the 80's. However, if you truly believe that, you need to consult and to studies to find out how to improve it. To come forward with these changes would devalue these wetlands. We know that you are just doing this to facilitate the kind of development that we don't need right now.

Based on the consultation guide provided, I have significant concerns with the changes proposed. These concerns include the following:
1. It is unclear who the ultimate approval authority will be for changes to wetland designations and boundaries under various pieces of legislation (Planning Act, EAA, ARA, NEPDA, etc.). You have not presented any evidence why this shouldn't remain with MNRF.
2. It is unclear who the ultimate holder of the wetland data will be. I strongly recommend that this role remain with MNRF or another appropriate Provincial service.
3. It is unclear how many times a wetland can be re-evaluated and which re-evaluation is the appropriate one.
4. This new system removes the watershed lens and may result in impacts that extend outside of a municipal boundary, with no Provincial or conservation authority oversight to review the bigger picture. I am opposed to this change in governance for the systems and believe that it will have negative consequences for natural hazard and natural heritage management in Ontario.
5. The removal of the wetland complex concept will serve to dramatically reduce wetland features on the landscape, increasing flood and drought risk, and reducing habitat, biodiversity and ecosystem services. I am opposed to this change and believe that it will have negative consequences for natural hazards and natural heritage in Ontario.
6. It is unclear if the guide is suggesting that the recent or future elimination of a wetland for agricultural purposes (Page 9) would cause a wetland to not be considered such any longer. It is also unclear if such changes would allow for the removal of wetlands in advance of Planning Act applications under the guise of agriculture.
7. MNRF has a long history of natural resource management. It is unclear why the consultation guide is proposing to remove all references to MNRF as a source of data for undertaking wetland evaluations. I am opposed to MNRF being removed from a role here as it will negate decades of experience and corporate knowledge.

Wetlands are beautiful. You could measure them in terms of flood protection in the face of a changing climate, biodiversity, number of species at risk, water purification, among others. Or, you could just go outside with your family, breath deeply, and know that some things are just worth protecting. I welcome a fulsome approach to updating OWES with these goals in mind, but I do not feel that is what the intent of this government is at the moment.