30 October 2015

The Greenspace Alliance today sent in responses to questions posed in a July 2015 Discussion Paper (7.8 MB) from the Ministry of Natural Resources and Forestry on Wetland Conservation in Ontario (EBR #012-4464).  Key points made include that we should start from the position of protecting all wetlands, as do Quebec and Alberta, and that the legislative framework needs to be strengthened to be more protective of wetlands.

The full submission is here.

Ken McRae’s comments on this discussion paper, as well as on the Conservation Authorities Act review, are here.  Comments by the Ontario River Institute are here.

8 August 2016

In a second round, the Ministry has posted another discussion paper (EBR 012-7675), 56 pp., 9.7 MB.  Comments are due November 16, 2016.

November 2016

We received draft comments from Ontario Nature as well as a submission by Fragile Inheritance Natural History (Fred Schueler and Alina Karstad).  We drafted our own letter, supporting these excellent comments and adding some of our own for emphasis.  However, in the end, we co-signed, along with 34 other environmental organizations, the Ontario Nature submission.  Earlier, ON had already sent a similar letter to the Minister, endorsed by 17 organizations.

20 July 2017

The EBR posting generated 654 comments. Significant changes to the strategy were made as a result, including strengthened targets by including a baseline, a more aggressive timeline and achieving a net gain in areas where wetland loss has been the greatest (i.e. in southern Ontario).

The final document is here:

http://apps.mnr.gov.on.ca/public/files/er/a-wetland-conservation-strategy-for-ontario-2017-2030.pdf

The Ministry clarifies that the development of a wetland offsetting policy will be a distinct process, and involve further consultation with all sectors.

31 July 2017

In an email dated July 31 to the co-signatories of their submission, Ontario Nature provides an analysis of the Wetland Conservation Strategy issued on July 20:

Improvements:

1. 1. Provincially significant wetlands and Great Lakes coastal wetlands will continue to be off limits to development. Current policy protections will be upheld as the government develops a new wetland offsetting policy. Bogs and fens will also be ineligible for offsetting. Offsetting is to be used only as a last resort (pp. 42 – 43).
   2. The 2030 target for the overall strategy has been strengthened from “no net loss” to a “net gain” of wetland area and functions in southern Ontario where wetland loss has been most pronounced (p. 27).
   3. The Province has committed to specific timelines to improve Ontario’s wetland inventory and mapping. Priority areas will be identified by 2018, and mapping and evaluation will be done by 2020. Collaboration with Indigenous communities on wetland mapping and information is also to occur in 2018 (p. 41).
   4. Stronger language regarding engagement of Indigenous communities (pp. 35, 45).
   5. “Sustaining biodiversity” is included in the vision statement (pp. iii, 27).
   6. New references to climate change adaptation and mitigation considerations (e.g., pp. 25, 33, 35).
   7. New references to other complementary provincial initiatives and policies (e.g. the Pollinator Health Action Plan (p. 23) and the Provincial Parks and Conservation Reserves Act (p. 15)) suggesting, hopefully, that there is some recognition that implementation of the strategy requires integration with other policies and initiatives.
   8. A commitment to develop performance measures and prioritize actions to meet targets (p. 35).
   9. A commitment to develop policy guidance to inform local planning (e.g., natural heritage system planning) (p. 35).
   10. Subwatershed/watershed planning is specifically mentioned as something to be considered in the development of the offsetting policy (p. 43).
   11. A commitment to promote green infrastructure (like wetlands) as an alternative to traditional infrastructure (p. 35).
   12. The specific outcome of revamping the wetland evaluation system is that “conservation of wetlands will be improved.” (p. 45).

Shortcomings:

1. 1. The 2025 target is “no net loss” which means we likely face another 8 years of wetland loss (p. 27).
   2. The draft target to identify and conserve Ontario’s significant wetlands by 2025 was dropped.
   3. The list of actions in the policy section is still a shopping list with no timelines attached (p. 35). (Though three actions continue to be identified as priorities: wetland inventorying and mapping; offsetting policy; evaluation system update (pp. 40 – 45).)