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   Comments on Criteria, methods, and mapping of the proposed regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe, EBR Registry Number:   013-1014


 Ministry of Natural Resources and Forestry

 To: Ala Boyd

  Content of letter:

 A. Ontario Nature Comments, we agree with

 B. Our Comments (followed by MNR Ministry letter, newspaper article and study by WWF and our photos).

  A.We agree with below comments prepared by Ontario Nature:

  1. The Government of Ontario’s wetland offsetting policy should outline the provincial government’s role and responsibilities in developing guidance, protocols and performance standards; setting up and managing reliable, publicly accessible information systems; authorizing and recording offsetting transactions; and monitoring and enforcing compliance.

 2. The wetland offsetting policy should set clear, measurable performance standards to ensure consistency in program implementation and enable evaluation of program outcomes.

 3. The Government of Ontario should commit to providing sufficient funds and expertise to effectively administer and oversee the wetlands offsetting program.

 5. The Government of Ontario should assign an independent body, such as the Environmental Commissioner of Ontario or a standing committee of experts and stakeholders, to provide regular, periodic review and evaluation of the wetland offsetting program.

 9. The wetland offsetting policy should apply across Ontario to all key drivers of wetland loss, including infrastructure development and drainage works that are currently exempt from Provincial Policy Statement prohibitions.

 11. The wetland offsetting policy should ensure that provincially significant wetlands and significant coastal wetlands are strictly off limits to all forms of development, and that current protections under the Provincial Policy Statement and other provincial land use policies are upheld or strengthened.

 14. The replacement ratio(s) for wetland offsets should be based on net gain, assuring that the tangible, on-the-ground benefits the offset provides exceed the corresponding losses (i.e., in area, function, Indigenous cultural values). The ratio(s) should reflect risk, uncertainty and time lags.

 15. The wetland offsetting policy should stipulate that in determining equivalence, wetland offsets must take into account the quantity (area) and quality of the wetland features and functions, their landscape context, and associated social and economic values. It should provide standards and criteria for assessing and comparing gains and losses.

 17. The wetland offsetting policy should define thresholds to be met for avoidance and minimization of adverse impacts, and include the consideration of alternatives Where efforts have been insufficient, the policy should direct regulators to refuse to grant authorizations for proposed developments.

 21. Averted wetland loss should be considered a valid offset only where it is demonstrated that securement of the wetland provides additional benefits to the baseline scenario, taking into consideration probable future threats and current or anticipated restrictions on the use of the site.

  B:  Our additional comments are based on protection of natural heritage in Courtice (Provincially Significant Harmony Farewell Lake Iroquois and Maple Grove Wetland Complexes) that would reflect concerns and solutions anywhere in GTA:

 The federal EA during Harper that reviewed the provincial EA for the extension of Hwy 407, especially Hwy 418 leading through the middle of Wetland Complex didn’t find anything wrong with removal of 13 ha of this natural heritage. This should not be allowed today, in 21st century of climate changes that are affecting our communities in more ways than one (this is causing now flooding, drought, severe winds, etc.).

 There is a need to mitigate this loss of wetland by adding the lands that could be rehabilitated in order to protect not only nature but people as well. MNR has chance to do this exercise in their new mapping, so that no additional loss would be allowed for the extension of urban boundary, etc. Without over-haul of provincial, federal and municipal EA’s Ontario fisheries and waterways within natural heritage will be unimaginable. Also, without defending of natural heritage at the OMB, during municipal planning exercises by the MNR even more natural heritage will be removed because developers site specific studies can easily prove that this loss will be satisfactory. Politicians are in many cases not experts on the environment and their decisions differ from conservation authority staff recommendations on development. This is the case in many municipalities – there is no science based decision in municipal planning (especially at the Durham Region).

 No protection of natural heritage in new Criteria, methods, and mapping of the proposed regional Natural Heritage System would end up being MNR’s legacy.  Our Municipality is already making plans for extension of urban boundary.

  Copy of MNR Minister to me in respect of expansion of urban boundary within Provincially Significant Harmony Farewell Lake Iroquois Wetland Complex is included:

 July 27, 2017

 Thank you for your email regarding an extension of the urban boundary in Courtice within the Municipality of Clarington. I regret the delay in responding.

  The Ministry of Natural Resources and Forestry does not have an approval role under the Planning Act and we cannot provide advice about the decision-making process related to urban boundary extensions in this area. Under the land use planning process, specifically when decisions are made to expand urban boundaries, the municipality would consider natural heritage features, including wetlands.

  In addition, any site specific development or activities that would interface with wetlands and other hydrologic features would be subject to review and approval by the local conservation authority and its regulatory powers under the Conservation Authorities Act.

  I encourage you to contact the municipality and, in this case, the Central Lake Ontario Conservation Authority, if you would like to further discuss the matter.

  Again, thank you for writing.


  Kathryn McGarry

 Minister of Natural Resources and Forestry

  Example of latest impact of Hwy 418 on wildlife as permanent barrier for their east to west and vice versa movement:


 Very recently, turtle hatchlings were killed trying to get from west to east over and or around this barrier. No solution was found by the Blackbird Construction Co. to provide crossing.

 I could send you photos of other wildlife death due to the same reason, not enough protection of Species at Risk or other wildlife due to the loss of natural heritage functions.

   Construction below the water table level, replacement of permeable soil by development on this special aquifer that is underlain by clay (red arrow) caused also two extreme conditions: flooding after precipitation and low water level in aquifer (red arrow is Hwy 418, yellow arrow is groundwater flow in this aquifer). Does this area need more impermeable surfaces? There are now remains of 2 very large wetland complexes that need connection and linkages. Only MNR can help to protect not only wildlife but humans. Survival of wildlife and Wetland Complexes functions depend on high water table in this aquifer.

 Water ponding in our parks and ditches currently threatens peoples’ health by West Nile virus and Lyme disease because the areas like these are excellent breeding grounds for ticks and mosquitoes. I live here more than 40 years and I was never threatened by these illnesses until now. I am living example of this impact. There were plenty of wildlife species consuming ticks and mosquitoes. There is a great need of rehabilitation of habitat for these species to protect public health. MNR has chance to protect us now.

  The whole of Ontario is in need of MNR help, participation (not only in turtle protection, as per bellow article):

 Turtle conservancies declare state of emergency in Ontario

 By Paige Phillips,

 Huntsville Forester,

 August 2 2017

  MUSKOKA — One of the world’s most ancient species is at risk.

 Of all turtles, snapping turtles are the best scavengers and vacuum clearness and in water are harmless and don’t snap.    only one per cent of eggs laid will reach adulthood

  The plans are an important step towards protecting and recovering biodiversity and supporting healthy, thriving rural communities, especially in an era of climate change.

  The Natural Heritage System plan identifies a network of forests, rivers and wetlands that provide essential habitat for wildlife. (ont. Nature -  Joshua Wise

  the proposed linkage areas connecting the core natural habitats are much too narrow – only 500 metres wide.

  The corridors are critical placeholders. Once identified, they would be protected from urban development, and would present opportunities for ecological restoration and stewardship over time.”

 Lastly, WWF loss of wildlife should be recognized by MNR in their new Criteria, methods, and mapping of the proposed regional Natural Heritage System of natural heritage: 05741821

  Thank you for consideration of our comments.

[Original Comment ID: 210952]