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Ontario Wetland Conservation Strategy and Evaluation System TECHNICAL PAPER Practitioner Observations and Comments

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Page 1: Ontario Wetland Conservation Strategy and …cms.savanta.ca/sites/default/files/2018-04/Ontario...• Wetland Complexing; and • Scoring. 4.1 Biological Component Most factors considered

Ontario Wetland Conservation

Strategy and Evaluation SystemTECHNICAL PAPER

Practitioner Observations and Comments

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1. INTRODUCTION

This summary report provides a compilation of observations and comments from practitioners in the natural and social sciences, related to the ongoing wetland conservation dialogue in Ontario. These comments are specific to the Wetland Conservation Strategy for Ontario (WCSO)(MNRF 2017) and the current Ontario Wetland Evaluation System (OWES) (3rd Edition, Southern Manual, updated in 2014)(MNR 2014). This self-funded, independent report is based upon the collective experience of experts who have been engaged in wetland evaluation, impact assessment and conservation, since Ontario’s first wetland policy and evaluation work in the early 1980s.

The highly specialized carnivorous wetland plant, Spoon-leaved Sundew is common and widespread in Ontario (photo credit James Leslie)

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ONTARIO WETLAND CONSERVATION PRACTITIONER OBSERVATIONS AND COMMENTS

2. THE WETLAND CONSERVATION STRATEGY FOR ONTARIO (WCSO)

The WCSO provides a comprehensive review of recent and current legislation, policies, guidelines, international agreements and the importance of collaboration as ingredients to the conservation of wetlands in Ontario. The Strategy is defined as a “roadmap”, so that the Ontario government and its partners continue to reach higher and further to ensure that wetlands remain an enduring part of Ontario’s landscape. The WCSO includes tentative steps towards improving OWES, and introduces the concept of potential wetland feature removal and replacement, subject to a future no net loss policy.

The Province’s strategy notes that “…wetlands are sensitive ecosystems – and they’re under pressure from land conversion, invasive species, pollution and climate change. Without action, our wetlands will be severely impacted with many likely to disappear in the face of these significant threats.”

In terms of pressure from land conversion, there has been a marked decrease in threats to wetland conservation since the early 1980s. The WCSO reports that, “68 per cent of the wetlands originally present in southern Ontario were lost by the early 1980s…”. An additional four percent were noted to have been lost since the early 1980s, with that rate of loss declining more recently (i.e., less than 2% loss during the period 2000 to 2011; OWCS Figure 3).

The slowing rate of wetland conversion can be linked, at least in part to the Planning Act and Provincial Policy Statement which prohibit development and

The Great Blue Heron depends upon wetlands for feeding

(photo credit Eva Lee)

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site alteration in significant wetlands. Effective implementation of the PPS and associated guideline documents (e.g., Natural Heritage Reference Manual) have been in place since the mid 1990s in Ontario.

Natural Heritage System (NHS) planning has also contributed to a decrease in the removal of significant wetlands and the expansion of wetland cover in settlement areas. Natural Heritage System (NHS) planning was described by Riley and Mohr (1994) and was explained in the 1999 provincial Natural Heritage Reference Manual (NHRM). It was expanded upon in the 2010 NHRM and now, under the Provincial Policy Statement (MMAH 2014), the identification of a NHS is a requirement for municipal planning in southern Ontario.

NHS planning in Greater Toronto Area (GTA) Settlement Areas, is resulting in larger and more functional ecosystems, which are increasing natural features and functions over existing, agricultural and rural landscapes (e.g., Mount Pleasant, Brampton; Boyne Secondary Plan, Milton).

Other factors that have slowed wetland loss and improved environmental features and functions in settlement areas of the GTA include:

• Improvements and advancements in watershed and subwatershed planning;

• The approval and implementation of Development, Interference and Alteration Regulations for all Conservation Authorities (Ontario Regulations 42/06 and 146/06 to 182/06) consistent with Ontario Regulation 97/04;

• Improved management of stormwater; and• Increased attention being paid to the role of

nature in climate change resilience.

Guiding Principles are presented in the WCSO, include a premise that all wetlands and their functions are important, including provincially significant, coastal wetlands, and locally and regionally important wetlands. This approach rests in part upon Ontario’s Wetland Evaluation System (i.e., OWES), that provides a relatively simple assessment tool

to determine what features meet the threshold for significance. As noted in the WCSO, the OWES is the only means to evaluate whether particular wetlands are provincially significant or not. For the provincial Strategy to be successfully implemented, the OWES would benefit from a critical technical review and modernization (discussed further in section 4).

The conservation of all natural and naturalized features in an urbanizing context presents particular challenges. Feature conservation encounters overlapping and competing land demands, attached to other provincial objectives (e.g., PPS section 1.1). Those include, for example, the need to promote: efficient development and land use patterns; standards to minimize land consumption and servicing costs; and, development and land use patterns that conserve biodiversity and consider the impacts of a changing climate.

The Province’s approach to “develop conservation approaches and policy tools to prevent the net loss of wetlands in Ontario …” is an intelligent one, and one that is overdue in Ontario. The dialogue around a no net loss approach allows for informed technical discussions regarding how to incorporate positive and effective wetland conservation within Settlement and urbanizing areas, where the potential for conflicting interests is high. This will help to limit and avoid inefficient and suboptimal outcomes, that seem to result from the rigid application of the current rules with limited attention to opportunities to improve outcomes.

The US moved in this direction in the early 1990s. They developed mitigation banking as a technique for off-setting wetland removals associated with various developments. In the US, the experience with wetland replication in mitigation banks resulted in many early failures and disappointments. Much has been learned about wetland creation through the past few decades in the US. The consideration and introduction of this approach in Ontario, is now better supported by science, with widespread successful and viable wetland creation/restoration examples.

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ONTARIO WETLAND CONSERVATION PRACTITIONER OBSERVATIONS AND COMMENTS

3. PRIORITY ACTIONS OF THE WCSO

The WCSO identifies three actions that have been prioritized above all others. These actions represent the Province’s policy approach for wetland conservation in Ontario. The Province intends to complete each of these Actions to ensure wetlands remain an enduring part of Ontario’s landscape.

These Actions are:

Action 1 – Improving Ontario’s Wetland Inventory and Mapping;

Action 2 – Creating No Net Loss Policy for Ontario’s Wetlands; and

Action 3 – Improving for the Evaluation of Significant Wetlands.

The timing of each Action is also important; these actions do not appear to be occurring concurrently. While mapping and wetland evaluation work continues, there is no apparent plan or schedule to improve the OWES (i.e., per Action 3 above). The Draft Wetland Conservation Strategy (MNRF 2016) noted that the end product of the review of OWES may be a new edition of the Ontario Wetland Evaluation System, or it may be a new approach to mapping and evaluating the significance of wetlands in Ontario. That language was deleted from the final Strategy (MNRF 2017), leaving it unclear whether the Province intends to revise OWES to address existing weaknesses and gaps. The result is uncertainty around much-needed improvements to the OWES.

The Province has appropriately raised questions about the need to improve guidance for evaluating the significance of wetlands in Ontario (e.g., revising the OWES to reflect recent advances in science

and knowledge; assessing whether some values that are not currently considered should be added; whether other values could be removed and whether some values should be re-assessed in light of new knowledge). Improvements are also identified related to the need for increased clarity where current guidance is limited.

Problems exist throughout the OWES and its application. Perhaps most apparent are the inadequacies associated with the rating and ranking of socio-economic and Aboriginal components, which misrepresent their value and are not aligned with practices suggested in the literature. The lack of consultation, community feedback, unclear weighting, and a misrepresentation of Aboriginal and Cultural Values illustrate the flaws in the OWES Social Component. Other components of the OWES have similar technical weaknesses and gaps.

Beyond these and other ranking and scoring issues, significant wetlands are not all the same; they can vary widely in their character, features and functions. The OWES approach applied in many areas of the GTA has resulted in the gathering together, or complexing of an array of wetlands. This approach has typically treated all wetlands in a complex as equally significant, despite differences in size, shape, form, or function. While this approach is generally reasonable and reflective of connected ecological and hydrological interactions across a landscape, there are many instances where the complexing approach is leading to ineffective and inefficient outcomes. These issues and others are discussed in the following sections.

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The Moose relies upon wetlands for important aquatic plant food sources (photo credit Shelley Lohnes)

4. OBSERVATIONS REGARDING THE ONTARIO WETLAND EVALUATION SYSTEM (OWES)

While the OWES as a whole merits a detailed technical critique and modernization, some preliminary comments are provided in the following, specific to:

• Biological Component;• Social Component;• Hydrological Component;• Species Features Component;• Wetland Complexing; and • Scoring.

4.1 Biological Component

Most factors considered in the OWES, treat wetlands as the same, regardless of the degree of formation of

features and/or functions. In settlement areas around the GTA and the Greater Golden Horseshoe (GGH) more generally, the landscape has been, and in many cases continues to be highly altered. Alterations have affected both features and associated functions. The most widespread disturbances on this landscape are historic, recent and current agricultural practices, including natural cover removal (e.g., hedgerow, hayfields), tile drainage, ditching, cultivation, and the application of pesticides and fertilizers. In the near urban areas, within and adjacent to settlement areas, some agricultural fields/operations have become abandoned or neglected. That has, in many cases, resulted in blocked/affected farm drainage, the abandonment of livestock/irrigation ponds, and

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less attention to cultivation in areas where drainage measures are in decline. These conditions frequently lead to wetland development, given the predominance of relatively tight, impervious till soils (e.g., Peel and Halton Till Plains, Haldimand Clay Plain).

In other situations, disturbance origins for wetlands have occurred in response to the decommissioning of industrial facilities/landscapes, and the abandonment of traditional landscaping practices, typically in response to program and funding reductions (e.g., reduction in intensive management of public lands). The resulting wetland features tend to be young, characterized by a degree of non-native and invasive plant species, and with stunted ecological functions relative to natural, non-disturbance origin features.

As written and interpreted, the OWES provides no distinction between wetland origin and/or viability. Hence, there are no score reductions or exceptions in the application of factors such as: productivity (e.g., wetland type, site type), or biodiversity (e.g., vegetation communities, diversity of surrounding habitats). A small “isolated” marsh resulting from recently abandoned agricultural production, dominated by the invasive Common Reed (Phragmites australis ssp. australis) can be, and often is treated similarly to an isolated, native sedge marsh derived from natural processes within the landscape. The result under current rules is the conservation of both features in situ without considering the potential for replication and enhancement.

4.2 Social Component:

The Social Component seeks to assess wetland functions and services that provide social value (both use and non-use values), economic goods and services, and are of, Aboriginal or cultural importance. The specific Social sub-components include:

• Economically Valuable Products;• Recreational Activities;• Landscape Aesthetics;• Education and Public Awareness;• Proximity to Areas of Human Settlement;• Ownership;• Size; and• Aboriginal Values and Cultural Heritage (this

component totals up to 30 “bonus” points).

While the scoring is established in a manner that is very clear to follow and easy to understand, it is very difficult to understand and justify the rationale for the scoring approach used.

The “use social values” (how the wetland is used and interacted with in present time) are also assessed along a scale of presence or absence of each variable. For example, a portion of the Education and Public Awareness score includes a ranking of Research and Studies, where evidence of long term research on a wetland merits a top score of 12 points and evidence of non-scientific reports on a wetland only a score of 5. There is no consideration of the quality of those reports, or their relative contribution to the scientific body of knowledge. This is similar to other social value scores, which seek to rate and score social values in absolute terms without understanding actual use, quality, or contribution to social life.

“Non-use social values” (how the wetland is valued by people regardless of their interactions with the wetland) are considered, in part, through Landscape Aesthetics. This is a function of both a wetland’s distinctiveness and its absence of human disturbance. “Non-use” values, often considered for their importance to future generations, are an elusive construct to measure. Its values are dependent on how people and communities view the space, how they value it, and how they hope for it to be used in the future. These values are not reflected in the OWES Social Component Score.

The overall scoring approach appears to be arbitrary and it is not clear why some attributes are given such a high maximum score while others a relatively low score. There is no rationale offered to justify the relative weight of each component. Also puzzling is the inclusion of Aboriginal or Cultural importance as a “bonus” score (discussed below).

Lack of Consultation

There is no public consultation or community input provided to either the scoring framework or the actual Social Component evaluation. The Social Component score is completed by a trained wetland

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evaluator, using available desktop information and professional judgement. However, the social value of places cannot be understood without real dialogue and consultation with community members and stakeholders. Without this consultation, the evaluation can be no more than a speculative exercise. It is the community, the nearby residents, the users who interact with the wetland, and the businesses that might depend on that land who need to participate in its evaluation. Speaking with community members in interviews, surveys, open houses, or even (at minimum) reaching out to nearby community leaders and groups needs to be done to have a fulsome assessment of the social value of a space or place.

Aboriginal Values and Cultural Heritage

While the lack of any kind of consultation is a major drawback of the OWES Social Component evaluation, the assessment of Aboriginal Values and Cultural Heritage is the area which requires the most improvement. Firstly, Aboriginal Values and Cultural Heritage values are not equal and cannot be compared. The OWES scores these as being one or the other, and will not allot points if both are evidenced in an area. Further to this, the points

are awarded either as “present” (30 points) or “not present” (0 points) and are considered as “bonus” to the overall Social Component Score of a possible 250 points.

There is so much more to Aboriginal and Cultural Heritage than can be captured in this binary score. No consultation is conducted, no feedback is sought from Aboriginal communities to confirm or refute a finding, and the actual total score is still lower than the scores for several other Social sub-components, including recreational, economic, and educational value. This scoring approach simply does not begin to capture the complexities of Aboriginal or Cultural significance.

4.3 Hydrological Component:

While this section of the OWES was the subject of relatively more recent revisions, it too requires a careful review. Many of the individual technical papers cited in support of this component (and the other components) are very dated and do not represent the most current understanding of wetland hydrology.

As with the Biological Component, there is no understanding or recognition of the role that

Current language within the OWES manual does not exclude features like this human-created wetland feature from PSW mapping

(photo credit James Leslie)

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ONTARIO WETLAND CONSERVATION PRACTITIONER OBSERVATIONS AND COMMENTS

disturbances have played and/or continue to play in the establishment and presence of wetland features on the landscape. This is especially the case for the marsh wetland type. Marshes are described in the WCSO as, “… the most recognized yet least common wetland in Ontario”. In the GTA and many locations of the GGH, however, meadow marshes (per the Ecological Land Classification System) are frequently encountered, many of which are the result of the alteration and/or abandonment of traditional farming practices. These usually small, disturbance origin and invasive dominated features are frequently “complexed” with relatively more natural and intact wetlands, resulting in a significant wetland designation for these features.

Some functions (e.g., flood retention) are not considered in the context of the relative proximity to major open water and/or absence of vulnerable receptors. This can lead to a mischaracterization of functions and scoring.

4.4 Special Features Component:

Species Rarity

Standards for species rarity have been published in available Regional Flora documents, over the past 25 years by well-regarded, former and current provincial scientists (i.e., Southwestern Region, Oldham 1993; Central Region, Riley 1989; and Southeastern Region, Cuddy 1991). However, those and other status reports are quite dated, and should be revised to reflect updated cumulative observations and records. They should also update and incorporate rules that set thresholds for the status of species (i.e., number of individual occurrences). The Status Lists should be subject to an ongoing and rigorous peer review process and should be handled in a transparent and accessible manner (i.e., posted and available for public review and comment).

While OWES specifically states that, “where no designation of ‘rare’ is made, local significance cannot be scored”, the practice exercised by some MNRF districts is to score species that have a local designation of “uncommon”. Clarity is required in the OWES regarding “rare” and “uncommon” species.

Since local status ranks are unlikely to be updated in the near future, weight placed on locally rare species should be reduced. The 20 points assigned for a single specimen of something that is likely provincially common and secure can inappropriately inflate scoring outcomes.

Upland Plant Species Within the Wetland

The OWES indicates that:

Rare plant species that are most commonly found in upland areas and occasionally in wetlands may be scored in some cases, if the area in which they are found is not part of a large upland area within the wetland. A determination of what should be scored will be made on a case by case basis upon discussion by MNR.

This approach has been used for a number of species, including Butternut, an endangered, non-wetland species that is not related to wetland functions. This approach and some of the species and areas selected for application with OWES, can unreasonably distort wetland scoring outcomes.

4.5 Wetland Complexing

4.5.1 General Comments

The 3rd Edition of OWES (MNR 2014) is meant to provide more detailed guidelines to delineate wetland complexes, or groups of wetland units with complementary biological, social, or hydrological functions. However, the guidance is still vague and leaves much room for interpretation. The three rules presented in OWES for wetland complexing, while a good start, do not provide enough guidance related to functional importance and/or relationships between wetlands. This is made more uncertain by different criteria and interpretations employed in different MNRF Districts; these approaches are not documented or publicly accessible.

Inaccurate and variable complexing approaches have contributed to reduced technical rigor and questions regarding the thresholds applied to determine whether an individual wetland unit merits complexing. In some cases, for example, tiny wetland

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areas (documented as small as 0.00 ha wetland areas on MNRF OWES reporting) are included in a complex because of the presence of some level of simple features or functions, which may be strongly influenced by seasonal weather conditions (e.g., presence/absence of amphibians). The complexing rules offer no technical thresholds for the reasonable interpretation and application of some criteria. An abundance of discretion prohibits transparent, replicable outcomes.

A definitive minimum size criteria for wetland units (individually and/or complexed) would be helpful. While 2 ha is “generally” considered the minimum, exceptions exist for wetlands that “provide habitat for wildlife or serve other ecological, hydrological, hydrogeological or social functions” or are deemed to provide “important ecological benefit”. This broad wording often results in the inclusion of small wetland pockets, many of which have marginal features and functions and are much smaller than 0.5 ha.

In addition, to the definition of a clear threshold, more rigor needs to be applied when determining significance of these smaller units. This includes

reference to the Natural Heritage Reference Manual (NHRM) (MNR 2010) and the accompanying Significant Wildlife Habitat Technical Guide (SWHTG) (MNR 2000). The NHRM represents the recommended approach to implementing Ontario’s natural heritage policies of the Provincial Policy Statement (PPS). The SWHTG offers a recommended process for identifying and confirming the presence of significant wildlife habitat through the identification of four criteria. These criteria include: habitats of seasonal concentrations of animals; rare vegetation communities or specialized habitat for wildlife; habitat of species of conservation concern; and animal movement corridors.

These documents should be referred to when reviewing small areas being considered for wetland complexing in order to help better define significance.

4.5.2 GTA Complexing Criteria

Aurora District of the MNRF developed and applied criteria regarding the potential to complex wetland units less than 0.5 ha in size (Table 1). These go beyond the guidance presented in the OWES. The

Table 1 – MNRF, Aurora District Wetland Complexing Rules for Smaller (less than 0.5 ha) Wetlands, unpublished

Criteria Number Complexing Rule

1 Occur in site districts where wetlands are very rare or rare (score of 60 or 80 points in the rarity within the landscape category see Table 4, Section 4.1 in the wetland manual).

2 Support wetland types not well represented elsewhere in a wetland complex.

3 Sustain significant species/communities (i.e., Rare or uncommon species/communities at the local, regional or provincial/national level, conservation priority bird species, or species of concern).

4 Are amphibian breading areas.

5 Function as migratory waterfowl stopovers, summer feeding areas or waterfowl breeding areas.

6 Are headwater sources or contribute base flows.

7 Are hydrologically connected to larger wetlands.

8 Provide intervening wetland habitat between larger wetlands.

9 Are kettle wetlands, an uncommon wetland restricted to moraines.

10 Occur along corridors.

Table 1 is based upon available, dated file information. These criteria are not published nor are they publicly accessible. Table 1 is assumed to include the most current criteria applied by the MNRF. The general complexing criteria in OWES and these small wetland criteria would benefit from a more detailed and rigorous review to improve outcomes. Summary comments regarding criteria presented in Table 1 follow, as input to a potential review.

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satisfaction of one criterion supports an MNRF decision for inclusion within a complex.

MNRF - Aurora District Criterion 1

Occur in site districts where wetlands are very rare or rare (score of 60 or 80 points in the rarity within the landscape category see Table 4, Section 4.1 in the wetland manual)

Further clarity on this criterion is required to prevent small pockets of early succession, anthropogenic wetlands from being included (such as small pockets of reed canary grass that are quick to establish and sometimes provide only marginal wetland functions). A refinement to this criterion could be the application of an exclusion for such marginal features. Consideration of replication and enhancement of such features, rather than conservation in situ, could provide important opportunities to achieve efficient and viable ecological outcomes, and the completion of complete and healthy communities.

MNRF-Aurora District Criterion 2

Support wetland types not well represented elsewhere in a wetland complex

If “support” is meant to refer to an area that provides supporting function to a wetland type not well represented elsewhere, then that aspect is likely encompassed in the other technical criteria. If is it only to refer to relatively under-represented wetland types, it would be better to refer to the listing of wetland types that are less common is their representative Ecodistrict. For example, if the marsh-type is considered common in that particular Ecodistrict, then this criterion should not apply, regardless of its rarity in the subject complex.

MNRF-Aurora District Criterion 3

Sustain significant species/communities (i.e., Rare or uncommon species/communities at the local, regional or provincial/national level, conservation priority bird species, or species of concern).

Rarity of vegetation communities should not be considered as it is not a technical characteristic included as part of the OWES evaluation. There is a great deal of variability of vegetation community titles in the province that reflect a variety of sources

and guidance documents (e.g., various drafts of Southern Ontario Ecological Land Classification; ELC, and Natural Heritage Information Classification; NHIC). Until further clarity is achieved, the ranking of vegetation community types results in potentially inaccurate outcomes and unnecessary complexities.

The presence of a single locally rare species should not be sufficient on its own to justify inclusion in a PSW complex. The local rarity ranks assigned to some species are based upon outdated status lists; further, many of these species are provincially common. Considering OWES defines provincial significance, it would be prudent to reconsider how locally rare species are addressed (e.g., cap on scoring; reliance upon regional/provincial rarity, only where status lists are current, and accessible).

MNRF-Aurora District Criterion 4

Are amphibian breading areas.

A well-defined measure of “amphibian breeding areas” is needed, such as the Significant Wildlife Habitat (SWH) threshold set by the MNRF (2015) for woodland and wetland (non-woodland) amphibian breeding habitat types. As currently used, an observation of an individual frog or toad in a disturbed feature can trigger the inclusion of that wetland unit within a complex. A measurement of function or a threshold for application would benefit the application of this criterion, rather its more frequent use as a presence/absence indicator.

MNRF-Aurora District Criterion 5

Function as migratory waterfowl stopovers, summer feeding areas or waterfowl breeding areas.

Wetland areas smaller than 0.5 ha are generally not large enough to meet the functional aspects defined by this criterion. The existing MNRF guidelines should be consulted to assess the local significance of waterfowl habitats. This includes Appendix M from the SWH Technical Guide (OMNR 2000) which describe both the categories for waterfowl population status as well as landforms that characteristically provide significant waterfowl habitat. By considering the category for each waterfowl species known to be present in the municipality with mapped landform information and the knowledge of interest groups,

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the degree of significance of waterfowl habitats can be better defined.

Three criteria listed in the OWES are addressed in the SWH designations (migratory waterfowl, stopover, and breeding area). Each category defines the requirements to meet SWH designation for waterfowl (e.g., number of individuals recorded, number of individuals recorded/day, number of species recorded, and specific types of species recorded. There is substantial information available within each Ecoregion to specifically describe each of the four significant waterfowl components described within OWES. The fourth (summer feeding area) is not specifically addressed by OWES, and requires consideration.

MNRF-Aurora District Criterion 6

Are headwater sources or contribute base flows.

As with other criteria, a measure of the degree of function is missing. A measure of the significance of the supporting hydrologic functions in headwater areas is needed to best define the relevance and utility of complexing. For example, this criterion should only apply if there is a measurable significant difference in the hydroperiod of surface water contributions to other downstream units of an existing PSW or wetland complex being evaluated (i.e., compared to conditions that would exist in the absence of the wetland unit).

MNRF-Aurora District Criterion 7

Are hydrologically connected to larger wetlands.

This criterion is relatively clear. Although it is implied that hydrological connections refer to either surface water or groundwater. A slight revision to accommodate both considerations would improve clarity.

MNRF-Aurora District Criterion 8

Provide intervening wetland habitat between larger wetlands.

As currently worded, any feature of any size could be included (e.g., narrow drainage ditches and tiny pockets of reed canary grass in an agricultural fields). An assessment of degree of function and thresholds for inclusion would be more helpful. Minimum thresholds (e.g., size, relative cover of wetland indicator species, degree of connectivity) are required to add meaning to this criterion.

MNRF-Aurora District Criterion 9

Are kettle wetlands, an uncommon wetland restricted to moraines.

This criterion is relatively clear, although a minimum size should be provided. This size threshold should be based on a review of the average size of kettle wetlands that are known from Ontario. It should exclude features that are not distinct kettles and/or contribute only limited and/or localized functions.

MNRF-Aurora District Criterion 10

Occur along corridors.

This criterion is vague and imprecise. It is not clear what this criterion is intended to address - on its own, the presence of a small wetland within any type of corridor should not trigger significance. If these wetland units merit PSW designation, their significance should reasonably be expected to be triggered by one of the other nine criteria. There needs to be a more refined definition of “occurring along corridors” - one with a narrower focus, or the use of this criterion needs to be abandoned.

If this criterion continues to be used, it would be wise to define clear thresholds (e.g., limited to contiguous wetlands that persist along naturally occurring watercourses and floodplains). Recognizing that some corridors include some very narrow strips of wetland, a minimum overall size and a minimum average width should be defined.

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5. CRITIQUE OF SCORING APPROACH

Once technical aspects of OWES and complexing are reviewed and modernized, the overall wetland scoring approach, would also benefit from review. A final score of 600 out of 1000 (60%) results in a wetland being deemed to be provincially significant. The OWES does not provide a rationale for the threshold; presumably, this is in alignment with a general commitment to conserve most wetlands

as provincially significant. The WCSO notes that all wetlands are to be deemed to be important and subject to conservation. The establishment of low scoring thresholds for overall significance can undermine the integrity of the OWES and lead to questions regarding the relevance of the significance designation.

Any evidence of amphibian breeding activity within this isolated 0.1 ha disturbance-origin wetland feature, allows it to be included within a PSW

complex regardless of more suitable breeding habitat within the local landscape (photo credit James Leslie)

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6. CONSIDERING WETLAND FUNCTIONS

The modernization of the OWES can contribute to improved conservation of important wetland features and functions in Ontario. Within that review, it would also be useful to look carefully at more accurately assessing wetland functions.

Wetland functional assessments have advanced over those defined in the US and Europe in the early 1980s. Hydrogeomorphic functional assessments have emerged as a preferred method in some jurisdictions. Functional assessments move beyond the rather simplistic approaches of OWES, and can provide a more precise measurement of functional importance. Those approaches take a more integrated water/ecology approach to the assessment of wetland functions and they depend less upon only the biological indicators of wetlands at surface. Some hydrogeomorphic approaches pay particular attention to biogeochemical cycling, and hydrologic functions. Some jurisdictions have also used hydrogeomorphic approaches to define the importance of headwater wetlands and surface drainage features (e.g., West Virginia and eastern Kentucky) (Noble et al. 2014).

The following aspects could inform a more comprehensive assessment of wetland functional importance:

• A more detailed understanding of wetland functions;

• Improved integration amongst ground, surface water and ecological functions;

• Improved understanding of how wetland functions change seasonally;

• Development of a wetland functional assessment framework to guide the evolution and refinement of the OWES.

Table 2 is a conceptual functional assessment framework that Savanta developed to better define wetland functions. It draws upon American and European models and guides aspects that need to be fully considered. The framework is a starting point that could be useful to inform a more broad dialogue and development of a provincial tool. Table 2 provides a checklist of functions. Its application to a wetland area and/or complex requires measurement of these functions using a blend of qualitative and quantitative measures.

It could be particularly useful as a measurement tool to more fully define functional importance and potential functional replacement requirements in terms of meeting the Province’s interest in moving towards a no net loss model. Substantial dialogue is required to better define how socio-economic and cultural components should be integrated within this functional assessment model.

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7. CONCLUDING REMARKS

The WCSO provides a comprehensive review of recent and current legislation, policies, guidelines, international agreements and the importance of collaboration as ingredients to the conservation of wetlands in Ontario. Guiding Principles presented in the WCSO, include a premise that all wetlands and their functions are important, including provincially significant, coastal wetlands, and locally and regionally important wetlands. The conservation of all natural and naturalized features in an urbanizing context presents particular challenges.

Feature conservation encounters overlapping and competing land demands such as the need for efficient development and land use patterns; standards to minimize land consumption and servicing costs; and, development and land use patterns that conserve biodiversity and consider the impacts of a changing climate.

The Province’s approach to “develop conservation approaches and policy tools to prevent the net loss of wetlands in Ontario …” is an intelligent one. To support that approach, the Province has recognized the need to improve guidance for evaluating the significance of wetlands in Ontario. The Wetland Conservation Strategy for Ontario appropriately raises questions around the need to improve the Ontario Wetland Evaluation System (OWES).

Problems exist throughout the OWES and its application. Perhaps most apparent are the inadequacies associated with the rating and ranking of socio-economic and Aboriginal components, which misrepresent their value and are not aligned with practices suggested in the literature. Other components of the OWES have technical weaknesses and gaps as do the approaches for complexing.

This summary report provides a compilation of observations and comments from practitioners in the natural and social sciences, as input to the ongoing dialogue in Ontario regarding improving wetland conservation outcomes. Especially important are ideas provided related to: improving the OWES and associated complexing rules and the ability to consider wetland functional assessment tools to link with and or replace some current OWES approaches.

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Report Prepared by:

Savanta Inc. Tom Hilditch*, President & CEO

Elise-Ho-Foong, Senior Climate Change & Socio-Economic Impact Lead

Shelley Hazen, Climate Change Specialist

James Leslie, Senior Vegetation Ecologist

Other Technical Contributors:

Heather Beam Noel Boucher George Buckton Peter Burke Shannon Catton Rick Hubbard Michelle Letourneau Shelley Lohnes Chris Zoladeski

*The principle author has been involved in wetland impact assessment work in Ontario since the early 1980s and was a member of a technical team which field tested the first edition of the Ontario Wetland Evaluation System (OWES).

References: Ameli, A. A. and I. F. Creed 2017. Quantifying hydrologic connectivity of wetlands to surface water system. Hydrology and Earth Science Systems 21: 1791-1808.

Bird Studies Canada (BSC) 2003. The Marsh Monitoring Program 1995-2004. A Decade of Marsh Monitoring in the Great Lakes Region. Available online: http://www.bsc-eoc.org/mmp10yrpt.html/.

Cuddy, D.G. 1991. Vascular plants of eastern Ontario. Ontario Ministry of Natural Resources, (former) Eastern Regional Office, Kemptville. Unpublished MS. 80 pp.

MNR 2010. Natural Heritage Reference Manual for Natural Heritage Policies of the Provincial Policy Statement, 2005. Second Edition. Toronto: Queen’s Printer for Ontario. Available online: http://www.mnr.gov.on.ca/289522.pdf. Accessed December 15, 2017. 248 pp.

MNR 2000. Significant wildlife habitat technical guide. Available

online: https://dr6j45jk9xcmk.cloudfront.net/documents/3620/significant-wildlife-habitat-technical-guide.pdf. Accessed Jan. 12, 2018. 152 pp.

MNRF 2014. Ontario Wetland Evaluation System, Southern Manual, 3rd Edition, version 3.3, 2014.

MNRF 2015. Significant Wildlife Habitat Criteria Schedules for Ecoregion 7E, 6E and 5E. Available online: https://dr6j45jk9xcmk.cloudfront.net/documents/4776/schedule-7e-jan-2015-access-vers-final-s.pdf. Accessed Jan. 12, 2018.

Ministry of Natural Resources and Forestry (MNRF) 2016. Draft: A Wetland Conservation Strategy for Ontario 2016 – 2030.

Ministry of Natural Resources and Forestry (MNRF) 2017. A Wetland Conservation Strategy for Ontario 2016 – 2030. Queen’s Printer for Ontario. Toronto, ON. 52 pp.

Ministry of Municipal Affairs and Ministry of Housing (MMAH) 2014. Provincial Policy Statement. Available online: http://www.mah.gov.on.ca/Page215.aspx

Noble, C.V., Summers, E.A., and Berkowitz,J.F. 2014. Validating the Operational Draft Regional Guidebook for the Functional Assessment of High-Gradient Ephemeral and Intermittent Headwaters Streams in Western Virginia and Eastern Kentucky. U.S. Army Engineer Research and Development Centre, Vicksburg, MS.

Oldham, M.J. 1993. Distribution and status of the vascular plants of Southwestern Ontario. Draft. Aylmer District, Ontario Ministry of Natural Resources. 149 pp.

Riley, J.L. 1989. Distribution and status of the vascular plants of Central Region. OMNR Open File Ecological Report SR8902. 110 pp.

Riley, J. L. and P. Mohr. 1994. The natural heritage of southern Ontario’s settled landscapes. Ontario Ministry of Natural Resources, Southern Region, Aurora. 78pp.

Varga, S., editor 2005. Distribution and status of the vascular plants of the Greater Toronto Area.

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Table 2: Wetland Functional Assessment Framework

HYDROGEOMORPHIC LANDSCAPE POSITION

• Size• Ground water functional relationship (i.e., prominent recharge/discharge)• Riparian• Isolated Catchment

REGULATING SERVICES

• Carbon sequestration and storage• Local climate and air quality• Moderation of risks (i.e., floods, storms)• Erosion Prevention• Pollination

WATER - Hydrological

• Conveyance• Floodwater and flow regulation, storage• Erosion control/shoreline stabilization/sediment stabilization• Quality and temperature effects• Sediment/toxicant reduction and retention• Organic contributions - invertebrates and debris• Biogeochemical processes - cycling, removal and/or storage

LAND & BIOTA

1. Terrestrial Habitat

• Decomposition processes• Biological diversity• Community structural diversity• Species richness• Productivity• Soils formation

2. Aquatic Habitat

• Biological diversity• Community structure• Species richness• Productivity

3. Specialized Habitat

• Seasonal concentration areas: deer, waterfowl, reptiles, bats• Specialized habitats:

- Area-dependent- Colonial nesting- Winter mammal cover- Waterfowl nesting- Amphibian breeding- Turtle nesting- Seeps and springs- Mineral licks- Vegetation communities at risk- Confirmed Provincial SAR

• Special Considerations- Long-term landscape presence- Settlement period creation/ alteration- Recent history/Current Disturbance/Alteration

Note: Savanta Inc. developed this functional assessment framework from a variety of domestic and international resource materials

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Ontario Wetland Conservation

Strategy and Evaluation SystemTECHNICAL PAPER

Practitioner Observations and Comments