I am writing to express my…

I am writing to express my unqualified opposition to the proposed changes to the Ontario Wetland Evaluation System (OWES). One would think that, with both a biodiversity crisis and a climate crisis at hand, the province would be moving to enhance wetland protection, not decimate it. I expect the province, especially the MNRF, to be careful custodians of our natural resources rather than its liquidators. The proposed changes more closely resemble a development industry wish list rather than responsible government policy.
My specific reasons for opposing these changes include the following:
- The province's own Housing Affordability Task Force stated that a shortage of land isn't behind the current housing shortage. As such, there is no need to pave over wetlands to ease the housing crisis as the document misleadingly suggests.
- Wetlands are crucial to reducing the risk of flooding events which are predicted to rise as a result of climate change. The proposed changes will not only lead to a loss of the buffering capacity of wetlands, but also lead to more housing in flood-prone areas. No doubt, the province (public) will be asked to provide compensation when inappropriately-sited housing areas experience flooding.
- Wetland losses in many areas of southern Ontario already exceed 85%. How high do you wish to take that to - 100%? It's hard to hold other areas of the world to account for the protection of their natural heritage when our own track record is so dismal (and getting worse). It seems lost upon the government that healthy ecosystems are the underpinning of a healthy economy, not an impediment to it.
- The proposed policy would no longer recognize or consider wetland complexes. This "slice and dice" approach to evaluating wetlands will lead to many smaller wetlands losing their provincially significant status. This change blatantly caters to developers who wish to see the protections currently afforded PSWs eliminated. If granted, it would lead to the systematic dismantling of PSWs piece by piece until little or nothing remains. Clearly the goal here is not the protection of wetlands but, instead, the elimination of protections for wetlands.
- The proposal to no longer recognize threatened or endangered species is another "cut" designed to further weaken protections by seeing that fewer wetlands qualify for protected status. Again, the goal here is clearly to erase protections under the guise of "streamlining".
- Under the proposed changes, MNRF would remove itself from the wetland evaluation process leaving the process with no oversight body or central record-keeping system. This is a disastrous proposal that would leave assessments in the hands of evaluators working for developers with no oversight or any checks and balances. Furthermore, without MNRF serving as a central record-keeper, there would be no centralized mechanism for uploading evaluations for future access by the public or by private organizations. Instead, we would have a "hodgepodge" of local records that would be inaccessible to many. Lastly, how would MNRF achieve the targets set out in its Wetland Conservation Strategy for Ontario, 2017-2030 if it is removed from the wetlands evaluation and record-keeping process?
- It has not escaped the notice of many that these proposed changes are being made at the same time as many other proposals that will have far-reaching, negative impacts on environmental protection. One could be forgiven for thinking that this is a deliberate strategy designed to overwhelm the public and NGOs so as to limit their meaningful participation in the consultation process. The short timelines provided to respond are equally problematic.
- The stated impacts of the proposed changes conveniently omit the inevitable negative natural heritage implications. Instead, it focuses only on the impacts on businesses which MNRF describe as neutral to positive. How irresponsible to gloss over the significant negative impact these proposals will have on natural heritage protection, public safety and public finances.
In summary, I am calling on the government to withdraw, in their entirety, the proposed changes to the OWES. In all my years of advocating for natural heritage protection, this is one of the most cynical pieces of legislation I have yet to encounter. I do not believe that it is the result of recommendations of MNRF staff at the ground level; rather, I believe it is being imposed on them from above, leaving many conscientious workers in this ministry to potentially defend or implement the indefensible.
Please put your duty to the public good over the interests of the development lobby and withdraw these proposals.
Thank you.