ERO 019-6160 Comments re…

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

General Observations:

The Ontario Wetland Evaluation System (OWES) is one of many tools that are used to help to make Ontario livable. Wetlands provide vital recreation opportunities, employment, protection and filtration of potable water, act as carbon sinks with their abundant vegetation, provide erosion control, do nutrient cycling, recharge groundwater, conserve the flora and fauna that cannot speak for themselves, and are environments for our future citizens to enjoy.
It is sobering to note that Ontario has lost about 70% of its wetlands in the last 100 years and 20% of Ontario’s Species At Risk survive on those same lands. OWES has and is a vital tool to use for reserving, conserving, and preserving Ontario’s remaining wetlands.
Here’s what will happen if the vital tool of the OWES is altered to suit outside interests:

1) Under the proposal, significantly changing the OWES for Provincially Significant Wetlands (PSW) means that in near future very few wetlands will be designated as provincially significant;

2) Therefore, many of the present PSWs might lose their protective designation potentially exacerbating the already great loss of this landform;
3) No recognition or consideration of wetland complexes (i.e., wetlands that are connected hydrologically) a benchmark by which many wetlands - especially small ones - are determined to be provincially significant;

4) Wetland boundaries can be arbitrarily remapped without having to re-evaluate the whole wetland;

5) No recognition of Species At Risk in the evaluation process, a benchmark which is currently a key reason in the determination of provincial significance;

6) Removal of provincial government oversight of the evaluation process, with no central agency assigned to actually coordinate, approve evaluations, and ensure that information about PSW designation is publicly available.

Here are some recommendations:

a) The OWES must be left as is to help in the designation of wetland types in Ontario;

b) Use OWES in its present form as a useful tool to help Ontario to adapt to Climate Change
and its effects;

c) The government must be responsible to the people of Ontario – not outside interests. Hence, it can ensure that the province’s wetlands are properly evaluated by the OWES.
d) It must be remembered that there are many types of wetlands. Some wetlands exist as part of a complex, some in conjunction with rivers and lakes, and some by themselves. One cannot simply call them all “wetlands”. There are wetlands and wetland complexes.

e) No size limit should be put on wetlands.

f) Wetlands that are left in Ontario, provide vital environments for Species At Risk. So, they must not be altered in any way. You cannot just recreate a wetland that has taken hundreds or thousands of years to develop. Wetlands MUST be left as they are without the interference of humans.

g) Consultation with Indigenous Peoples is not apparent in this process. These Peoples have a knowledge base dating back more than 50 000 years to before they came to North America from Asia via the Bering Strait. Their view of the environment is valuable. They can provide insight into how wetlands can be protected.

Conclusion:

I see no reason to alter the Ontario Wetland Evaluation System. It is not an impediment to the building of residential infrastructure. The desire to alter large portions of OWES is an expedient to cater to outside interests which do not have the welfare of ALL Ontario citizens at heart. As a reminder, it is the responsibility of the provincial government to represent the people of Ontario and not outside interests. OWES is a fine tool, AS IS, to be used to reserve, conserve, and preserve the Wetlands of the province of Ontario now and into the future.

Thank you for the opportunity to express these thoughts.