If the proposed changes to…

Numéro du REO

019-6160

Identifiant (ID) du commentaire

72277

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

If the proposed changes to the Ontario Wetland Evaluation System (OWES) go ahead, here's what will happen and the problems this will created.

No more wetland complexing, and existing provincially significant wetland complexes can be broken apart, with each small wetland re-evaluated separately. The problem with this plan - water does not respect boundaries. It flows and will find its natural connections within the complex. Wetlands cannot be assessed separately.

The threshold for significance remains the same, so an individual wetland must attain the same score as the much larger wetland complex to remain significant. The problem with this concept - as we see when a beaver dams a stream, suddenly we have a lake and downstream dries.

The score for threatened and endangered species will be eliminated. Instead of scoring 250 points previously, they will score 50 points as "provincially significant" species. The problem - where is the evidence that the risk to threatened and endangered species is reduced because a decision has been made to separate wetlands? The risk is unchanged by artificially drawn lines on a map.

The Province will have NO role in reviewing or approving wetland evaluations. In fact, the Province will no longer keep wetland evaluation files or maintain significant wetland mapping. Nor will it provide information for use in wetland evaluations. This decision provides a stronger argument for expanding the authorities of the Conservation Authorities to encompass these roles previously a responsibility of the Province.

All responsibility will be delegated to local planning authorities such as municipalities. BUT... the municipalities will have NO authority to review and approve wetland evaluations. The problem - this plan provides no increased funding for adding the necessary expertise at the municipal level and the funding will be greater than what is required at the provincial level. BUT the government apparently has considered this problem and solved it - with NO authority to review and approve wetland evaluations what does access to funding and expertise matter anyway.

The changes say explicitly that a wetland evaluation will be considered "complete" when it is "received" by a planning authority. This is a very distressing conclusion. Will the government also use this precedent to degrade the importance of a professional engineer’s stamp when evaluating the safety of plans for infrastructure construction?

The wetland evaluator will only be accountable for the objectivity and accuracy of the wetland evaluation to the person paying for it. The problem - Ontario’s natural heritage “belongs” to all of us not land developers, not government. It is hard to believe: the property owner or developer seeking to remove the significant wetland designation will be the only authority determining if the wetland evaluation is valid.

Finally, the proposed changes to OWES make it clear that the Province intends to remove protections for provincially significant wetlands from the Provincial Policy Statement, in favor of some sort of "offsetting" policy. The problem - natural ecological areas are complex and unique. They are not man-made. Eons and epochs have created their uniqueness. There is no offsetting equivalency that makes this plan sensible.