OLTA supports all the…

OLTA supports all the recommendations and supporting arguments outlined in the submission from the Canadian Environmental Law Association to this consultation ERO Number 019-6160, The summary recommendations are as follows:

RECOMMENDATION NO. 1: CELA recommends that MNRF apply an equity lens in crafting the OWES.
RECOMMENDATION NO. 2: Sections of the OWES dealing with wetland complexes should not be removed.
RECOMMENDATION NO. 3: Sections of the OWES which provide for consideration of reproductive habitat and migration, feeding or hibernation habitat for an endangered or threatened species during the evaluation of a wetland should not be removed.
RECOMMENDATION NO. 4: The Ministry should remain the approval authority for all wetland evaluations completed under the OWES.
RECOMMENDATION NO. 5: The section of the OWES dealing with “locally important wetlands” should not be removed.

Plus, OLTA proposes the following:
Removing wetland complexes, and consideration of reproductive habitat and migration, feeding or hibernation habitat for an endangered or threatened species, during the OWES evaluation process will result in changes to lands that are currently identified as eligible under CLTIP. This will likely result in smaller areas of land trust lands being eligible for CLTIP, and increased taxes for land conservation charities, which could cripple these local community organizations.

Changes to OWES must ensure that the ability of land trusts and other landowners to conserve conservation lands is not negatively impacted. The Conservation Land Tax Incentive Program is an essential program for land trusts providing tax relief to conservation organizations focused on private stewardship of provincially important natural areas. These areas provide essential ecosystem services to local communities.

ADDITIONAL RECOMMENDATION: Any changes to the OWES should ensure that the value of existing conservation lands is not eroded.