I would like to point out…

I would like to point out the lack of transparency in this ERO posting, starting with the title. It seems dishonest to characterize the changes being proposed as “updates” when, in fact, sweeping changes are being made to the OWES including taking the whole OWES program out of the MNRF.

It also seems somewhat dishonest to suggest that these changes are demanded in the face of “Ontario’s housing supply crisis” when, in fact, these changes would apply to ALL development scenarios, i.e., commercial, residential and industrial. The government is using the housing crisis as a red herring to distract people from the wide range of policies that Bill 23 will change forever, if this Bill is allowed to become law.

The lack of transparency is also apparent in the MNRF’s summary of these changes. According to the MNRF these changes to the OWES are being proposed in order to:

• Add new guidance related to re-evaluation of wetlands and updates to mapping of evaluated wetland boundaries.
• Make changes to better recognize the professional opinion of wetland evaluators and the role of local decision makers (e.g. municipalities)
• Other housekeeping edits to ensure consistency with the above changes throughout the manual.

It may appear from this summary that these changes are minor in nature. But they are anything but that. Based on my review, these changes open up opportunities to remove the PSW designation for every wetland that has ever been evaluated as a PSW based on the presence of specialized habitat for Threatened and Endangered Species; will remove all references to the OWES in the PPS; will prohibit conservation authorities from providing their technical expertise based on the OWES to municipalities; will eliminate the practice of keeping wetland files and the role of the MNRF to provide assistance to Evaluators based on these files; will prevent conservation authorities from regulating the 120 metre setbacks from PSWs and 30 metre setbacks from evaluated wetlands, and will eliminate “wetland complexes”.

These changes are not minor.

My last comment concerns the lack of due diligence in posting this ERO notice. Members of the public have every right to expect more from the government than a downloadable version of the OWES manual with strikethroughs throughout sections to be deleted and additions inserted in blue font, especially when something as important as this is at stake.

It’s unfair and unreasonable to invite public comment on an ERO posting when members of the public are required to set aside many hours of their time just to sort through the proposed “updates” before they can even get started on a comment.

Every one of these changes could – and should – have been methodically listed in the ERO posting. The public has every right to expect full transparency from their government regarding changes that have such serious environmental and societal implications.