Dear ERO official, I am an…

Dear ERO official,

I am an ecologist, a naturalist and a resident of both southern and northern Ontario for nearly 50 years. I have spent much time throughout my life visiting wetlands for both work and recreation and I have great respect for their beauty, their bounty of biodiversity and for all the ecosystem services they provide for humans and wildlife alike. I have also lived and worked in the "Greater Golden Horseshoe" area and have witnessed first-hand the negative impacts of urban sprawl on southern Ontario's precious wetlands. I am concerned that the proposed updates to the Ontario Wetland Evaluation System (OWES), ERO 019-6160, will result in loss of protection for wetlands, thereby furthering the degradation and/or loss of these vital natural areas by opening them up for development. I know that we do not need to open up wetlands for development to solve Ontario's housing supply crisis - according to the 2022 report of the Ontario Housing Affordability Task Force, a shortage of land isn't the cause of the problem. Furthermore, filling in wetlands for development is costly to undertake and results in many more long-term costs for immediate neighborhoods by reducing flood control and water purification. With the notable increase in severe weather events, we must ensure that these natural buffer areas are protected, for everyone's sake. There are other solutions to helping solve Ontario housing crisis.

My biggest concerns with the proposed updates to the OWES are:

- The apparent removal of the MNRF from the evaluation and approval process. MNRF has subject-matter experts that can provide valuable unbiased support to an evaluator, and it will be difficult to access support like this elsewhere. Also, without MNRF overseeing evaluations, what will be the process to verify information and approve evaluations? Although all evaluators are trained at performing wetland evaluations, there should be an objective process for approving scores and designations without the bias that could (intentionally or unintentionally) be introduced by consultants and decision-makers with a vested interest in a specific wetland's final designation.

- The lack of clarity regarding who the decision-makers are that will receive and act upon completed evaluations.

- The apparent lack of any process (whether by MNRF or another group) to review, verify and approve completed evaluations.

- The removal of the consideration of Wetland Complexes from the evaluation system, thus allowing individual wetlands within a complex to be re-evaluated and potentially considered no longer significant. This idea conflicts with the concept (described in the Southern Manual pages 39-41, but slated for removal) that "Wetland complexes are commonly related in a functional way, that is, as a group they tend to have similar or complementary biological, social and/or hydrological function. Much of the wildlife in the area of the complex is variously dependent upon the presence of the entire complex of wetlands, with each wetland unit contributing to the whole". I don't believe the science on this has changed, so I believe this proposed change will endanger critical wetland systems along with all the functions they provide.

- The removal of any scoring to be applied for identified habitat for Endangered and Threatened species. Many of southern Ontario's wetlands support important (and in some cases the only) habitat for these species at risk of extirpation or extinction and they should be recognized (and scored accordingly) for this critical role they play. We are in the midst of a biodiversity crisis and any actions that make our rare species more vulnerable to loss cannot be tolerated.

Please consider the wide-reaching long-term ecological, financial and social implications of these proposed changes. Wetlands contribute billions of dollars in economic benefits to Ontario each year; they are more valuable to our overall economy when left alone versus when they are filled in and developed. It does not seem prudent to spend time (and money) re-evaluating wetlands to see which ones can be destroyed for development under these new rules. Keep the existing protections in place, as they are there for good reasons. Look within our existing serviced urban land areas for property to support more housing.

Thank-you for your time and consideration.