Wetland evaluations are a…

Wetland evaluations are a fundamental cog in the identification and protection of wetlands in southern Ontario. I have been certified to evaluate wetlands as a consultant since 1995, and have delineated hundreds of wetlands in southern Ontario since that time. I am constantly reminded when I visit wetlands how important they are in protecting our natural heritage – small wetlands often support plant and animal species and specific habitats that are not within an adjacent larger wetland. The proposed changes to the wetland evaluation system will likely cause the loss and degradation of a large proportion of the wetlands in southern Ontario. Below is the rationale for this statement.
a) Page 7: Wetland Re-evaluations and Mapping Updates and page 26: Wetland Complexes: Wetlands should not be evaluated as separate units only. Wetlands in the southern Ontario landscape are highly dependent on each other, hydrologically and ecologically. I do not know of any research that would contradict the interconnectedness of wetlands, unless they are completely isolated by major roads or urban development. The past history of farming eliminated many wetlands and reduced others, but the connections provided by the farming landscape and small watercourses remained and allowed wetland dependent wildlife to include many wetlands in their daily and seasonal activities. Frogs and salamanders cross long distances, breeding in one wetland, and using others as stepping stones to reach forests that provide habitat in summer and winter. Birds sing from one wetland, forage in another, and nest in another. Turtles cross farmlands from one wetland to another in search of resources, especially if a wetland dries up during the course of the year – one research project found that Painted Turtles, our commonest species, crossed unexpectedly long distances to reach what they perceived as suitable wetlands, and that often the wetland they reached was not the closest wetland. Plant species travel along small watercourses between wetlands with specially adapted seeds and vegetative fragments to maintain their populations.
Hydrological (surface water) and hydrogeological (groundwater) connections between wetlands are so critical that without complexing, many wetlands will be deprived of their water source. Urban development has major impacts on groundwater and surface water, and maintenance of unconnected wetlands will be rendered even more difficult by the need to consider wetlands separately.
I recommend that the distance between wetlands in a complex be re-examined with consultation and reference to current research, with particular reference to current research in urbanizing areas, but complexing should not be summarily discarded as the connections within wetlands are so important.
b) Page 20: Wetlands Bordered on Lakes and Rivers: this special case allows complexing of wetlands up to 30 m. Connections between wetlands in southern Ontario extend far further than the proposed 30 metres. Wetland wildlife commonly travel more than 100 metres between wetlands. The Ontario Wetland Evaluation System (OWES) manual’s reference to a distance of 750 metres between wetlands of a complex has been in place for forty years, and was based on science and has stood for 40 years of practice. It is not unreasonable, given the distance that wildlife can travel between wetlands. However, I recommend that this distance be re-examined, but in consultation with experts.
c) Page 26: Wetland Size: The stipulation that a wetland smaller than 2 ha must meet the criteria for Provincially Significant Wetlands to remain significant sets an impossibly high bar. The point scoring system was derived with wetlands larger than this in mind. With this criterion, a large proportion of the wetlands in southern Ontario will be deemed non-significant, with consequent loss of the biodiversity, ecosystem functions and hydraulic functions that these wetlands provide. Many highly sensitive wetlands with multiple ecological functions are currently the mainstay of wetland functions in southern Ontario. I recommend that consultation be conducted to determine stronger criteria for the inclusion of small wetlands in a complex but that this provision remain.
d) Page 54: Regionally and Locally Significant Species: the proposed removal of references to MNRF documents that list regionally and locally significant species will remove an important source of information. MNRF and Conservation Authority staff are generally the only source of this regional and local knowledge. Very few municipalities have lists of regionally and locally significant species. In all but a handful of cases, municipal staff do not have the expertise to develop such lists. An important component of the value of wetlands, to protect our regional and local biodiversity, will be scrapped. While it is acknowledged that the lists are in some cases dated, most are relevant, and these lists remain the only source of information. The lists should be updated. MNRF expertise is highly valuable, and should not be eliminated.
e) Throughout Document: Removal of Requirement to Consult with MNRF: MNRF have unparalleled expertise concerning wetlands in southern Ontario. To eliminate MNRF oversight from wetland evaluation will contribute to the cumulative loss of wetlands in southern Ontario that I believe will follow from implementation of Bill 23. The expertise within MNRF should be maintained and enhanced, not ignored.