I am submitting the attached…

I am submitting the attached comments on behalf of the City of Ottawa.

The City of Ottawa believes that the proposed changes to the OWES would lead to a dramatic loss of wetlands and harm to their benefits in Southern Ontario. This would be on top of the historical loss of wetlands, which reaches more than 90% in some counties. The changes contradict well understood wetland science. They would undermine decades of planning decisions, with adverse effects on natural heritage and municipal plans. They are intended to solve a problem that does not exist. Finally, they are unnecessary, because the Community Infrastructure and Housing Accelerator already provides a valid mechanism to address site-specific instances of conflict between Provincial planning priorities of growth and wetland protection.

The City makes 10 recommendations in its submission. The main recommendation is as follows:

Recommendation 1: the proposed changes to the Ontario Wetland Evaluation System should be withdrawn and a multi-stakeholder working group, including municipalities and Conservation Authorities, struck to consider and recommend any necessary updates to the system.