The following proposal raise…

The following proposal raise many concerns such as:
-The benefit of having a third-party regulate wetlands is that they can assess the features from a landscape level. In the proposed updates to OWES plan, how will a municipality determine which components of a wetland can be removed from a complex without understanding the features located outside of their jurisdiction?
-Who will ensure that wetlands that cross a local municipal boundary are assessed consistently?
-How do we determine the sensitivity of a wetland without considering rare species inhabiting these features?
-Which agency will be responsible to assist an evaluator in interpreting components of the evaluation system in a consistent manner if the MNRF is no longer accessible for this service?
-What checks in balances are in place to ensure that the evaluator is in fact using professional judgment to make decisions, especially if the municipalities don't have the resources to have qualified experts.
-What is the scientific and evidence-based rationale for removing wetland complexing?
-Why is the direction on locally significant wetlands being removed? This removes municipalities from creating and protecting their natural heritage system.

The Province should investigate the following to assist with streamlining development review when it relates to wetland protection:
-Provide an OWES light protocol: A full evaluation is not always warranted. If a wetland does not have provincial designation, the planning authority’s role is simply to delineate the boundaries of the wetland and determine the appropriate setback based on existing policies. Only in higher level-study planning processes does a wetland evaluation need to be carried out on unevaluated wetlands. Although it’s helpful to understand the OWES process, there should be a training program that is condensed for staff only tasked with delineation of the feature.
-Lack of training availability: The MNRF is the only agency currently offering OWES training. It is expensive and located away from most Southern Ontario practitioners. Has the government considered outsourcing the training to a reputable organization that can offer these provincially recognized protocols closer and more cost effectively in Southern Ontario?