I’m writing to express my…

I’m writing to express my opposition to the removal of several key components of our Ontario Wetland Evaluation System (OWES). One of the most concerning segments involves the removal of any discussion of, or evaluation of, wetland complexes. Our wetlands function as complexes, and it’s critical to our understanding and protection of our hydrological features that we continue to evaluate wetlands as such. There are no “efficiencies” to be found in attempting to understanding natural features while ignoring how they work. The critical ecosystem services provided by wetlands - absorbing excess water during flood events, holding and slowly releasing water during drought events, cleaning water as it moves across the landscape - require wetlands to function both biologically and hydrologically. All the wetland functions we rely on will be jeopardized in complex wetlands that are no longer recognized and afforded appropriate protections.

The wholesale removal of Sections 4.1.2.1 and 4.1.2.2, concerning Reproductive Habitat for Endangered or Threatened Species and Migration, Feeding or Hibernation Habitat for an Endangered or Threatened Species, are also greatly concerning. The beginning of Section 4.1.2.1 section reads “The protection of endangered and threatened species and their habitats is necessary in order to slow or prevent the extirpation of species from the province, and, in some cases, to help prevent their extinction on a global basis.” This passage and its associated wetland scoring criteria reflect our current biodiversity crisis across the globe. At least 20 percent of Ontario’s Species at Risk are directly dependent on wetland habitats (Ontario Nature). Southern Ontario has already lost 70% of its wetlands (Ontario Biodiversity Council 2021), and the removal of these components of OWES will only accelerate our already catastrophic biodiversity loss across the province.

The province’s own Housing Affordability Task Force stated that “Greenbelts and other environmentally sensitive areas must be protected, (…)” (Report of the Ontario Housing Affordability Task Force 2022) and acknowledges that we need not build on environmentally sensitive lands to provide homes for all Ontarians who require them. I encourage you to reconsider these changes in order to PROTECT the future homes of Ontario's from floods, droughts and the ravages of climate change.