I wish to express my…

I wish to express my concerns and opposition to the proposed updates to the Ontario Wetland Evaluation System, for a number of reasons.

I personally live in relatively close proximity to a Coastal Wetland complex that does have protection through the current WES, that does have a very practical and real positive impact in balancing water levels and flooding in our neighbourhood, that does face real housing development pressure (not affordable housing), and that would highly likely lose its protection status and be lost within a short period of time if this proposal moves forward.

However, aside from my personal exposure on a micro-level, my concerns are even more profound in consideration of the broader effects of this proposal.

We all feel more exposed to the direct adverse effects of climate change, with more intense precipitation and flash floods, and it is widely known and accepted that healthy wetlands do have a critical role in flood control, water filtering, and groundwater recharge and discharge. In a situation where we need to invest into stronger protection and preservation of existing wetlands today to avoid much higher catastrophe relief costs in the future, this proposal removes several layers of protection for those wetlands, reducing the barrier to destroy them for development of housing. This happens after the province of Ontario even under its current government has spent billions in previous years to protect and restore wetlands in full recognition of their importance.

The approach taken here seems illogical in that it removes protections for a relatively small but critically important portion of Ontario's land, while there is by no means a shortage of land already zoned and ready for development is does not require protection and can accommodate the overall goal of Bill 23 to build 1.5 million homes. Those homes don't need to be built on wetlands for this plan to become reality.

I am also very concerned that the onus of wetland evaluation is proposed to be transitioned from local conservation authorities equipped with the skill set and existing trained staff to perform those evaluations in an efficient manner for an entire watershed, to municipalities who don't have staff with the expertise needed and who are already widely understaffed to perform their planning function under current legislation. This proposal will result in more backlogged planning processes at municipalities, higher staffing costs to municipalities who need to find and hire staff able to perform evaluations, and ultimately higher property taxes - exacerbated by the many other additional burdens placed on municipalities by proposals for other areas of Bill 23. Conversation authorities are much more effective in evaluating wetlands, both financially as well as in terms of their competency, and should remain in charge.

The scoring criteria for wetlands should remain unchanged, or the threshold for attaining “protected” status lowered to reflect and maintain the rationale that governs the current Ontario Wetland Evaluation System.

Furthermore, wetlands should continue to be evaluated as a wetland complex and not just individual wetlands, as looking only at an individual component might not reflect the actual relevance of a system of adjacent or connected wetlands.

The proposal as it stands today should not move forward. It does not help to achieve the goals of Bill 23, but in the opposite it will put many residents of those 1.5m new homes at risk as they are no longer benefiting from the protections our current wetlands provide to them and all of us.