RE: Concern About Proposed…

RE: Concern About Proposed Updates to the Ontario Wetland Evaluation System 2022-10-25

I am writing to express my deep concern about proposed changes to the Ontario Wetland Evaluation System. I live and work in Norfolk County, in the heart of the Carolinian Zone, the location of Ontario’s first Priority Place for Conservation, home to many Provincially Significant Wetlands and large wetland complexes. This County supports some of the highest biodiversity in Canada. Our wetlands are very important to the health of many Species At Risk; they also support a wide range of recreation and tourism; they are an important natural water recharge and purification system, they support pollinators our extensive farms need, and they have an important place in the history and culture of Norfolk.

The Ontario Wetland Evaluation System is a very technical document, researched and written by wetland ecology experts with the MNRF. It helps protect some of our most fragile Species At Risk in Ontario, which require very specialized wetland habitat to survive. We are facing ongoing and accelerating species extinction across Canada and around the world. Our Species At Risk require habitat to breed in, live, and migrate. Without wetlands to support these life stages, we risk losing many of these species forever. Southern Ontario is within the Carolinian Zone of Canada, and has some of the highest biodiversity in Canada. We need to be looking at ways to support this incredible natural heritage, not reasons to change areas which are not suitable for housing or any development in the first place, and which give us so many “ecosystem services” in return. I don’t understand why these changes are being made under the guise of assisting in the building of homes - good planning does not include intentionally developing wetlands.

The proposed changes that concern me include:
Seriously downgrading the evaluation of individual wetlands,
Removing local and traditional references and sources of species knowledge (a lot of naturalists are species experts by training or interest),
Removing the role of expert MNRF staff to help the Ontario Government and municipal/county governments to protect these very complex and important natural habitats.
Removing references to wetland complexes. The science relating to the importance of wetland complexes hasn’t changed - why are these sections being deleted?

Here are some reasons why we should be maintaining and strengthening the current Wetland Evaluation System:

Wetlands are irreplaceable habitats, providing homes to Provincially and Federally Endangered and Threatened reptiles, amphibians, birds, insects (including pollinators) and plants. Wetland complexes are important for natural water control, and for the survival of species that use the entire complex. Our reptiles and amphibians in Ontario depend on wetlands for part or all of their life cycle.
It is our responsibility, and by extension, yours, to be good land stewards of wildlife and plant life in wetlands, and not endanger the survival of several vulnerable species through poor planning or greed.
Wetlands sequester carbon, helping to mitigate climate change in the communities where they are located.
Wetlands buffer communities from flooding. They work with existing natural waterways, ponds and lakes to naturally control water in times of high rainfall and snow melt.
Wetlands are an important source of passive and active recreation. Since the COVID pandemic, citizens of Ontario have realized how important natural areas are to their mental and physical health. Naturalists, hunters, fishers, canoeists, kayakers, wild foragers, and artists all value wetlands for their constant source of inspiration, wildlife, and plant life.

These are the actions I am asking you to take, in the name of good science:

Withdraw the proposed amendments that change the nature and effectiveness of the Ontario Wetland Evaluation System.
Simply make the “housekeeping” changes needed to keep up with correct current terminology and other minor edits. This does not include removing whole sections or changing the intention or effectiveness of the Wetlands Evaluation System.

Ontario’s Housing Affordability Task Force outlined in its 2022 report that we do not need to sacrifice environmental protection to address the housing crisis. That’s because “a shortage of land isn’t the cause of the problem.” (p.10) There is a vast supply of land already open for development within existing municipal settlement boundaries. You don’t need to weaken the Ontario Wetland Evaluation System in order to build houses, or for any other reasons. Please make a commitment to protect our wetlands - we need them now and will need them more in the future. For many of our Species At Risk, wetlands are already their homes.