The “Regulatory Impact…

The “Regulatory Impact Analysis” section states that the impacts of this proposal will be neutral/positive to businesses, but what about wetlands? What about Ontario’s natural flood mitigation and carbon sequestration system? There is so much more at stake here than business interests.

The proposed updates to OWES will make it more difficult for wetland complexes to be classified as PSWs. Many wetlands in Ontario are complicated interconnected systems made up of smaller components. These complexes of smaller components are equally as important as large stand-alone wetlands and should be considered as “the sum of their parts”, not as distinct individuals. The proposed changes to OWES would allow complexes to be split up and their components evaluated separately, which will make it more difficult for them to be classified as PSWs. This will significantly reduce the amount of PSWs in the province and open up vital wetland habitat for development.

Editing the OWES document to remove the consideration of endangered and threatened species when classifying a wetland is very concerning. Any wetland that is home to a species at risk is likely critical habitat for the survival of the species. Allowing development on SAR habitat will surely increase pressure on already vulnerable wildlife populations.

Furthermore, why is MNRF being completely removed from the process? MNRF staff have the specialized expertise required to evaluate wetlands; most municipal staff do not. Additional changes proposed in ERO 019-6141 would disallow municipalities from consulting with Conservation Authorities on matters such as this. Those with the expertise to speak out against development in sensitive natural areas should not have their voices silenced.

Please reconsider these major changes to OWES. In an era of climate uncertainty and extreme weather events we should be putting more emphasis on the value of wetlands, not less.