The whole pretext of the…

The whole pretext of the proposal to update the Ontario wetland evaluation system is to free up land for development to alleviate Ontario’s housing shortage. This is a preposterous assumption since wetlands are unsuitable locations for housing development and as many planning experts have stated there is adequate space elsewhere to accommodate Ontario’s housing needs.

Numerous problematic changes within the proposal include the following:
• Proposal to remove the presence of endangered or threatened species at risk as being a factor in wetland evaluation: Many of Ontario’s species at risk depend on wetlands for their survival. Removal of this consideration is not justifiable.
• Proposal to remove the concept of wetland complexes from evaluation of wetlands: An entire wetland complex provides greater benefits than the sum of its individual units. As the current OWES manual states: “Much of the wildlife in the area of a complex is variously dependent upon the entire complex of wetlands, with each wetland unit contributing to the whole.” Many wetlands currently classified as significant in Ontario are wetland complexes. Removal of the wetland complex concept would make wetland complexes vulnerable to declassification and susceptible to development pressures. The difficulty in evaluating each small unit of a wetland complex on its own would make future classification of significant wetlands much less likely.
• Elimination of provincial oversight: Removing MNRF staff from oversight of provincial wetland classifications would leave local municipalities with limited expertise to their own devices in evaluating the merits of an assessment made by an evaluator working for a development proponent. Also, future central tracking of wetlands classified as provincially significant would become problematic.

The proposed Updates to the Ontario Wetland Evaluation System present an outrageous assault on provincial wetlands. Please withdraw this proposal in its entirety.