Wetland Complexes The…

Wetland Complexes

The proposed updates have removed all references to wetland complexes. Under the current system, wetlands that were separated by upland ecosystems, but within 750m and related to each other can be grouped into one wetland complex. The removal of wording regarding complexes indicates that, in future evaluations, wetlands separated by upland ecosystems must be evaluated separately.

Complexes are a vital aspect of determining significance, as wetlands within them are biologically, socially and hydrologically connected (e.g., animals often move from one wetland to another within a complex). Furthermore, impacts on one wetland may affect another within a complex.

Removing complexes from the evaluation system will have deep implications for scoring and the ability to protect dispersed wetland pockets. A wetland complex can encompass a larger area and a diversity wetland types, therefore increasing the number of scoring components and total score. If each wetland within a complex is assessed separately there is a strong likelihood that each wetland will score lower than they would as a complex. This is concerning, as wetlands do not provide benefit in isolation.

Furthermore, the ability to re-evaluate individual wetlands within wetland complexes separately could result in the widespread, piecemeal down listing of PSWs.

Removing complexing and opening past complexes to individual assessment will result in artificially low scores in re/evaluations, which are not based on ecological sound assessments. We strongly urge that the proposed updates maintain the ability to complex wetlands that are demonstrably interrelated. We would suggest that if complexes have become over cumbersome, that the distance of 750m be reduce, not eliminated.

Endangered and Threatened Species

The proposed updates have removed Section 4.1.2.1 Reproductive Habitat for Endangered or Threatened Species and Section 4.1.2.2 Migration, Feeding or Hibernation Habitat for an Endangered or Threatened Species. These sections outline the scoring significance for Endangered (END) and Threatened (THR) species.

Under the current system, an END or THR species reproducing in the wetland would result in a PSW designation. This is because END or THR reproductive habitat is assigned 250 points for the biological component, and if a wetland scores above 200 in any component, it is considered Significant. Migration, feeding or hibernation habitat currently scores 150 points for the first species and 75 points for each additional species.

Under the new system, END and THR species will be scored under Sections 4.1.2.3 and 4.1.2.4 Provincially Significant Animal and Plant Species, which score points for any Species at Risk or species of Special Concern using the wetland for any part of its life cycle. However, species in this section receive fewer points and on a decreasing scale (50 points for the first species, +30 for the second, +15 for the third, +10, +5… etc.).

These changes will dramatically reduce their importance to the wetland score, and thus the protection a wetland may receive. We believe that, by the nature of their status, habitat of END and THR species should continue to trigger greater significance and protection. We strongly urge that the proposed updates maintain separate scoring protocol for the habitat of END and THR species. We would suggest that if END and THR habitat currently receives too high a score, that their scores be reduced, but not to the same level of other provincially significant species.

Agency Review

All references to input, guidance or decision making from MNRF or CAs have been removed in the proposed edits. This is concerning as these agencies have a wealth of knowledge regarding wetlands and their evaluation.

It also makes the evaluation process more ambiguous. Having one evaluating agency, (i.e. MNRF) previously meant that there would be consistency in the decisions made. The proposed changes have “decision makers” (i.e. municipalities) as the final recipients of wetland evaluations. Each municipality will have a different level of expertise. This means an evaluation system that was previously employed with consistency will have uneven application.

Furthermore, MNRF would previously update wetland mapping. If evaluations are considered complete once they are submitted to a municipality, will the municipality update the provincial mapping?