I am writing to express my…

I am writing to express my opposition to the proposed updates to the Ontario Wetland Evaluation System. Wetlands are critical elements of the natural system that sustains us. They retain and filter water, absorb run-off, absorb and retain huge amounts of carbon dioxide. Destroying wetlands by building over them degrades one of our most fundamental life support systems. We need to retain them to support our health and existence, not open them up for development.

In particular I oppose

1. the change that proposes that wetland complexes will no longer be considered in the designation of Provincially Significant Wetlands
2. the lack of recognition of endangered and threatened species as a criterion for designating significant wetlands
3. the reduction of clarity and details around wetland evaluation procedures, including ongoing consultation with the MNRF staff.
4. the removal of provincial oversight and coordination such that there will be no central record of PSWs in Ontario
5. the extremely short timeline to consider the implications of the changes
6. the greatly misleading and inaccurate analysis of the results of the changes that is presented on the ERO listing. The loss of more wetlands in Ontario will be devastating to wildlife, to the climate resilience of communities which they service, and to the sustainability of communities in their vicinity.

I recommend that:

1. Sections of the OWES dealing with wetland complexes should not be removed
2. Sections of the OWES dealing with the habitat, migratory areas, and feeding of endangered or threatened species be retained.
3. the Ministry of Natural Resources and Forestry should retain the authority to review and to approve all wetland evaluations completed under OWES.
4. The section of OWES dealing with 'locally important wetlands' should not be removed.

Real costs associated with the destruction of wetlands include losses of an estimated $15,171 to $17,968 per hectare per year in ecosystem services or a net present value of $500,000 to $600,000 per hectare within 3 generations. And these are generally considered to be underestimates by knowledgeable people.