October 16, 2015

Terese McIntosh, Program and Policy Advisor

Ministry of Natural Resources and Forestry
Policy Division
Natural Resources Conservation Policy Branch
Natural Heritage Section
300 Water Street
Peterborough, ON K9J 8M5
RE: Submission by Ducks Unlimited Canada on the MNRF Wetland Conservation in Ontario Discussion
Paper EBR Registry Number 012-4464
Dear Ms. McIntosh,
Ducks Unlimited Canada (DUC) commends the Ontario government on moving forward with the review
of Ontarios wetland conservation framework and the release in July of the Wetland Conservation in
Ontario discussion paper for stakeholder and public input. We are pleased to provide the following
comments on the discussion paper and our thoughts on moving forward with a new plan and stronger
policies for Ontarios wetlands.
Executive Summary
A new Strategic Plan for Ontario Wetlands will be a key step in improving wetland conservation.
However, in order to meet the governments commitment in 2014 to reverse wetland loss, the single
most important action needed to better conserve Ontarios wetlands is to develop an overarching,
comprehensive wetland policy to take full advantage of the suite of societal benefits that wetlands
providebenefits that are under increasing threat.
Despite our collective best efforts, wetland loss and degradation in southern Ontario continues, in large
part due to outdated provincial policies. The confusing patchwork of legislation and policies that relate
to Ontarios wetlands is burdensome to the conservation community, landowners and industry alike,
underscoring the urgent need for a new overarching, comprehensive wetland policy.
What would a comprehensive wetland policy for Ontario look like? At a minimum, we recommend that
it is an overarching policy that:
clearly sets out the Provinces long-term vision/goal, objectives and desired outcomes for
Ontarios wetlands, including a goal of net gain.
incorporates the mitigation/compensation hierarchy as a cornerstone of the policy; and
provides the policy umbrella under which all related policy must be consistent with.

The societal return on investment from stopping wetland loss and ultimately achieving a net gain in
wetlands is unequivocal. A comprehensive wetland policy would deliver clear benefits to the Ontario
government, the public, landowners, industry and other stakeholders. More specifically, the main
benefits of a comprehensive wetland policy (and in turn more, healthier wetlands across Ontario) are:

Increased community resilience to extreme weather caused by climate change; a substantive

investment in natural green infrastructure to help combat climate change will pay big dividends,
financially and environmentally
o Wetlands do double duty in the fight against climate change by aiding with mitigation
(i.e. carbon sequestration) and adaptation (i.e. flood and drought mitigation). Thats
why wetland conservation should be a key element in the Provinces soon-to-bereleased climate change strategy.
o Using a combination of natural green and grey infrastructure for stormwater and water
treatment infrastructure (vs. just grey infrastructure) will generate substantial cost
savings for the Province and municipalities over the long-term.

Improved water quality

o By removing phosphorus and other contaminants, wetlands play a big role in purifying
the water in our lakes and rivers and the water we rely on for many human uses.
o More wetlands in southwestern Ontario will help Ontario meets its recent commitment
to reduce phosphorus loading into Lake Erie by 40% by 2025. Wetland protection and
restoration is also playing a key role in restoring the water quality and ecological health
of Lake Simcoe.

Healthier Great Lakes and watersheds across the Great Lakes basin
o Healthy abundant wetlands improve groundwater recharge, help maintain adequate
stream flows, and reduce shoreline erosion.
o By shoring up the Great Lakes, wetlands also help underpin the $4.4 Trillion economic
output of the Great Lakes basin.

Greater biodiversity and the host of associated ancillary benefits

o Wetlands are home to over 600 species of plants and animals (including many species at
risk) and are second only to rainforests in terms of biodiversity.
o Enjoyment of wetlands and other natural areas increases public health and overall wellbeingin addition to providing hands-on educational opportunities.

A path forward and more certainty for industry that balances the need for wetland conservation
with sustainable economic growth.

Given that several Ministries and stakeholders will see a direct benefit from a comprehensive wetland
policy, we strongly recommend that the new strategic plan and comprehensive policy be supported and
implemented by all relevant Ministries in the Ontario government, with leadership provided by the
Ministry of Natural Resources and Forestry.

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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
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Ducks Unlimited Canada is encouraged by the consideration of a No Net Loss policy in the discussion
paper; and we particularly support the adoption of a mitigation/compensation hierarchy in order to
achieve no net loss, and ultimately a net gain of wetlands (and their benefits) in Ontario. We believe the
most effective way to achieve a net gain in wetlands is a combination of a mitigation/compensation
hierarchy to address on-going development, and large-scale restoration across southern Ontario to
ensure future sustainability and a healthy landscape.
While DUC strongly supports the use of a mitigation hierarchy to address unavoidable wetland loss, we
recognize there are some habitats that are too valuable to replace e.g. Great Lakes coastal marshes. For
those types of wetlands, we recommend that the new policy framework does not permit the mitigation
hierarchy to be applied.
We support the use of mitigation hierarchy to strengthen the protection of wetlands, given that current
provincial land use policy only affords protection to approximately half of the wetland area in southern
Ontario (leaving those wetlands more vulnerable to loss and degradation).
Ducks Unlimited Canada is also pleased to see the recognition in the discussion paper of several policy
exercises currently underway that afford excellent opportunities to strengthen wetland conservation.
The ultimate success of any new policy and strategic plan for Ontarios wetlands will largely depend on
allocating the appropriate resources by government and other stakeholders. And, as noted previously,
there is very strong, science-based evidence to support much greater investment by government in
Ontarios wetlands.
Moving forward, the province may wish to consider drawing upon the collective expertise of a variety of
stakeholders including industry, and establish a task force to consider the input received on the wetland
conservation discussion paper and formulate recommendations for next steps. A task force may play a
further role in formulating implementation tools and details, should the government move forward with
a no net loss policy including a mitigation hierarchy.
Through its operations across Canada, DUC has gained valuable hands on experience as the delivery
agent for wetland and upland habitat compensation projects. In those jurisdictions, we work closely
with proponents to manage compensation projects that meet or exceed the requirements of provincial
policy and regulations.
We look forward to discussing how DUC can continue to support the development of a strengthened
policy framework and a new strategic plan for Ontarios wetlands, including a mitigation/compensation
hierarchy. We believe these wetland initiatives will deliver clear, tangible benefits to current and future
generations of Ontarians, both environmentally and economically.

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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
Tele: (705) 721-4444 Fax: (705) 721-4999 du_barrie@ducks.ca

Our responses to specific questions put forward in the Discussion Paper:

1. Do you think there are current challenges related to wetland conservation in Ontario? If so,
what are the challenges?
Despite the best efforts of government, NGOs, landowners and other stakeholders, wetland loss
in Ontario continues to this day. Between 1982 and 2002, an average of 8,600 acres (3,480 ha)
of southern Ontario wetlands alone were lost each yearresulting in the cumulative loss of
72.5% of pre-settlement wetlands (a conservative estimate). And the State of Ontarios
Biodiversity 2015 Report indicates that, although the rate of loss has lessened since then,
wetland loss continues. As well, there are clearly losses of wetland function across the
landscape due to human activities in proximity to wetlands, even where wetlands remain
physically intact.
Perhaps the single most significant challenge is the lack of an overarching, comprehensive
policy for Ontarios wetlands. Please see our response under Question 4 for more detailed
comments and recommendations concerning the wetland policy framework.
The lack of adequate funding and other resources allocated to wetland conservation (e.g.
protection, restoration, management, research and monitoring) is another major, long-standing
challenge. Given the wealth of evidence that supports the value of wetlands in fighting climate
change and tackling other pressing environmental and economic challenges faced by Ontario
and its residents, we believe that a substantially greater investment in wetland conservation by
the Ontario government is clearly warranted and that this investment should be linked to
infrastructure considerations.
Wetlands and other forms of natural green infrastructure can, and should, play a key role in
mitigating and adapting to extreme weather caused by climate change, addressing persistent
water quality and supply issues, addressing biodiversity loss, and providing a higher overall
quality of life for Ontarians. To fully capitalize on these and other wetland benefits, appropriate
consideration for Ontario wetlands within the context of Ontarios infrastructure investments is
needed.
2. Three priority areas of focus for wetland conservation in Ontario are proposed: strengthen
policy, encourage partnership and improve knowledge. What do you think of these three
focus areas? Do you have other ideas for additional focus areas?
The three proposed focus areas appear to be broad enough in their scope to potentially capture
all the key activities that are required to reverse wetland loss.
Of the three proposed focus areas, DUC strongly recommends that the Province puts the
Strengthen Policy area as the top priority, since that area requires the most urgent action i.e.
stronger, clearer policies under the umbrella of a new overarching/comprehensive wetland
policy.
See our response under Question 4 for more detailed comments and recommendations
concerning the wetland policy framework.

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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
Tele: (705) 721-4444 Fax: (705) 721-4999 du_barrie@ducks.ca

3. Considering the three priority areas of focus, what are some actions and activities that
government, organizations, and individuals could take to improve wetland conservation in
Ontario? What partnerships should the Ontario government explore to stop wetland loss?
Strengthen Policy:
As noted previously, DUC recommends that the first priority to improve wetland conservation in
Ontario should be the Strengthen Policy focus area; and the first action in that regard by the
Ontario government should be the development of Ontarios first comprehensive wetland
policy, that provides the policy umbrella under which all wetland related policy must be
consistent with. An important component of a comprehensive policy is a
mitigation/compensation hierarchy (or sequence) that first seeks to avoid wetland impacts, then
minimize or mitigate impacts and, as a last resort, requires compensation, in the form of habitat
replacement for impacts which cannot be avoided or adequately minimized.
Other key actions are to take advantage of on-going policy initiatives (e.g. those identified in
Section 3.2 of the discussion paper) to strengthen wetland policy. Its essential that the
Province capitalize on these current exercises to better conserve Ontarios wetlands and put
those stronger policies into action as soon as possibleeven if a comprehensive wetland policy
is still being developed concurrently.
See our response under Question 4 for more detailed comments and recommendations
concerning the wetland policy framework.
Improve Partnerships:
Ducks Unlimited Canada in Ontario has a proven track record as a trusted partner of the Ontario
government that follows through and has delivered results for over four decades. We continue
to work collaboratively in a number of province-wide partnerships to advance wetland
conservation including the Ontario Eastern Habitat Joint Venture and the Great Lakes Wetlands
Conservation Action Plan. Also, we are directly responsible for helping to build capacity for
wetland restoration in Ontario through the transfer of wetland design and restoration expertise
to a host of regional/local partners such as stewardship councils, conservation authorities,
municipalities, other NGOs, and various industry partners.
Qualified partners with the appropriate expertise are a critical component of a mitigation
hierarchy that enables compensation under certain conditions. Compensation services must be
provided by qualified service providers to ensure quality habitat. Additionally, drawing upon the
collective expertise of conservation organizations and industry will be critical to the successful
implementation of a no net loss concept and mitigation hierarchy that DUC feels is key to the
future of wetland conservation.
Improve knowledge:
Ducks Unlimited Canada in Ontario with support from our Institute for Wetlands and Waterfowl
Research and conservation partners undertakes important research concerning wetlands; and
we are committed to communicate research findings to leaders in government and industry to
inform the development of stronger policies, programs and best management practises. For
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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
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example, DUC is currently leading a research project to better understand the role of southern
Ontario wetlands in mitigating the impacts of flooding with funding from private industry and
support from Ministry of Natural Resources and Forestry (MNRF) and Credit Valley
Conservation. In 2014, DUC in collaboration with Western University completed a study that
clarified and quantified the role of southern Ontario wetland in sequestering carbon. Also in
2014, DUC released a report by a leading ecological economist that quantified the return on
investment in DUCs conservation programs the author reported that for every dollar that DUC
invests in wetland conservation, Canadians enjoy $22 in economic, ecological and societal
benefits1.
Another key area of knowledge building that DUC continues to support is measuring the trend in
wetland cover (i.e. loss and gains in wetland area), in partnership with MNRF, Environment
Canada, and other partners. We believe that regular, standardized monitoring of wetland
extent, particularly in southern Ontario is essential to track our collective progress towards
stopping the net loss of wetlands, and ultimately a net gain in Ontario wetlands and their
benefits.
Additional focus areas:
The province should promote, invest in and support the securement of significant wetlands via
land trusts and non-government organizations; and also provide support for the public sector
(e.g. municipalities, CAs etc.) to secure significant wetlands and hold them under public
ownership.
Over the next decade, Ontario is at risk of losing large sections of Great Lakes coastal wetlands
currently held in private ownership (e.g. hunt clubs) as land ownership changes as a result of an
aging demographic. These large areas of coastal wetlands (e.g. St. Lukes Marsh) are at risk of
development without effective policies to protect them, and without support for securement.
The cost to secure these lands is too high for even the more well-resourced non-profit
organisations. Creative solutions must be developed to secure and protect these lands.
4. What do you think about Ontarios current wetland policy framework? Can it be improved?
Can it be made more effective? If so, how?
The current policy framework is fragmented, burdensome and simply not effective enough in
conserving Ontarios wetlands (as evidenced by the on-going loss of wetland area and function).
As noted previously, we continue to lose wetlands at a faster pace than we can restore them;
and the current system promotes unnecessary conflict among stakeholders. The reality is that
Ontarios population and economy will continue to grow, putting even greater pressure on
wetlands. Current wetland-related policies and legislation in Ontario are scattered across a
complex multi-jurisdictional framework (the discussion paper refers to some, but by no means
all of the legislation, policy and regulation that relate to wetlands, in one way or another). The
patchwork of legislation and policies that relate to wetlands is burdensome to the conservation
community and industry alike; which underscores the urgent need for a new strategic plan for
Ontarios wetlands, and a new comprehensive wetland policy.

Anielski, Thomson, and Wilson (2014). A Genuine Return on Investment. Prepared for Ducks Unlimited Canada

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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
Tele: (705) 721-4444 Fax: (705) 721-4999 du_barrie@ducks.ca

In addition to the analysis of wetland loss across a landscape, there are valuable insights to be
gained by looking at wetland loss at the site level. Ducks Unlimited Canada and others have
documented many examples of policy gaps resulting in wetland loss (and imminent wetland
loss), including the following:

The case of St. Lukes and other coastal marshes in southwestern Ontario:

In 2008, a 120 acre (49 ha) wetland called Triangle Marsh located in the Municipality of
Chatham Kent, across the road from St. Lukes Marsh, was converted to agricultural use. In
2009, 50% of the Winter Line Wetland on a neighbouring property was also lost to a
competing land use. The former wetlands were both classified by the Ontario Wetland
Evaluation System (OWES) as Provincially Significant Wetlands (PSWs) and coastal wetlands
with known presence of species-at-risk (e.g. King Rails at Triangle Marsh).
The St. Lukes Marsh was sold in 2013 for $3.5M (DUC was not in a financial position to
purchase the wetland in order to afford its protection). A private agricultural interest
purchased the property. Considering the two recent cases of wetland loss, DUC and others
feel the risk of St. Lukes of being drained and converted to agricultural use is real and
imminent. We believe these cases of major wetland loss point to significant gap in
provincial policy as relates to agricultural activities. The St. Lukes case also illustrates a gap
in wetland protection policies due to varying technical definitions of what constitutes a
wetland (e.g. differences in the Planning Act and Conservation Authorities Act definitions),
and therefore which policies are triggered (and which are not).

The case of wetland designation and drainage in Goulborn Township, in the City of
Ottawa

This case highlights the challenges of protecting wetlands through the land use planning
system when the Drainage Act is invoked. The Goulborn Wetlands were confirmed (and
reconfirmed) by MNRF as provincially significant; consequently, MNRF requested that the
City of Ottawa designate these lands accordingly in their official plan. Landowners objected
to the wetland status and argued that the wetlands were formed because of poorly
maintained drains and that the designation would lower property values. In response to a
landowner petition, a creek running through the Goulborn Wetlands was declared a
municipal drain (under the Drainage Act); and the City agreed to drain the land to preexisting conditions. According to the Environmental Commissioner of Ontario, the
wetlands in question were to be re-evaluated 5 years after the drainage improvements are
completed essentially when the wetlands are drained of their provincially significant
status.2
The case of Ontario Municipal Board approval of a plan for urban development in the
Regional Municipality of Waterloo (RMOW)
In 2013, the Ontario Municipal Board ignored the RMOW official plan by approving a
sprawling development. The impact of this decision was that over 2,470 acres (1,000 ha) of
2

Environment Commissioner of Ontario (2010). Ontario Planning Act Review

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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
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rural land beyond urban boundaries are to be developed, instead of the 210 acres (85 ha)
urban expansion area the RMOW approved. Urban development at this scale (particularly
when its located outside the Greenbelt) will almost certainly cause loss and/or degradation
of wetlands and other natural areas. Part of the Regions official plan that the OMB
overruled was a policy that sets an intensification target that exceeded the minimum target
established in the Growth Plan for the Greater Golden Horseshoe (exceeding the minimum
targets is allowed under the Growth Plan). Critics of this decision have stated that it was
tantamount to the OMB creating new provincial planning policy.
Consideration should also be given to ensuring consistency between various policies with
respect to the definition of a wetland. Wetland protection is compromised, approvals for
development can be unnecessarily delayed, and costly legal challenges may result when two or
more policies that have different wetland definitions are triggered. The definitions and other
language in the various policies concerning wetlands must be clear and consistent (in particular
between the Planning Act and Conservation Authorities Act, where currently wetland definitions
are not consistent).
However, and as noted under Question #1, the single most important change needed to
improve wetland conservation in Ontario is to develop an overarching comprehensive wetland
policy as this has the potential to address many of the current policy concerns. We recommend
that this new overarching policy should:

clearly set out the Provinces long-term vision/goal, objectives and desired
outcomes for Ontarios wetlands, including a goal of net gain.
fully recognize the full suite of social and economic benefits that result from
wetland conservation.
incorporate the mitigation/compensation hierarchy as a cornerstone of the policy.
minimize regulatory barriers to wetland restoration and management, and
provide the policy umbrella under which all wetland related policy must be
consistent with.

This is the type of policy solution that other jurisdictions like Nova Scotia and Alberta have
chosen to stop wetland loss; now its time to seriously consider a similar approach for Ontario,
thats designed specifically for and meets the needs of Ontarians.
5. Should targets be considered to help achieve wetland conservation in Ontario? If so, what
form should these targets take?
In general, wetland conservation targets are favorably viewed for their ability to inspire action
and provide a specific milestone to strive for; and could be a useful aid in measuring progress
towards the goal of reversing wetland loss. However, DUC recognizes that the development of
quantitative targets can be challenging and therefore should not be a prerequisite for the
development of an overarching policy. Targets could be considered at a watershed scale in the
practical implementation of a mitigation hierarchy that takes into account wetland diversity,
location, health and functionality.
6. The Ontario government is considering approaches to achieve no net loss of wetlands. a.
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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
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a. What do you think of the establishment of a mitigation/compensation hierarchy to

achieve no net loss? Are there other approaches?
Ducks Unlimited Canada strongly supports the establishment of a
mitigation/compensation hierarchy to achieve no net loss of Ontarios wetlands, and
over the long-term, to help achieve a net gain in wetlands. We believe this approach, as
part of a new comprehensive wetland policy, will provide a path forward for
government, industry, and the conservation sector that balances the need for wetland
conservation with sustainable economic growth.
More specifically, we support the establishment of a mitigation/compensation hierarchy
that would apply to certain activities that can impact wetlands including development
subject to the Planning Act/Provincial Policy Statement and the Place to Grow
Act/Greater Golden Horseshoe Growth Plan; and to infrastructure projects subject to
the Environmental Assessment Act. In the case of the Greenbelt Plan, Oak Ridges
Moraine Conservation Plan, Niagara Escarpment Plan, Lake Simcoe Protection Plan and
associated legislation, we do not support any lessening of current protections in place
for wetlands and other natural areas.
While DUC strongly supports the use of a mitigation hierarchy to address unavoidable
wetland loss, we recognize there are some habitats that are too valuable and/or too
difficult to replace e.g. Great Lakes coastal marshes. For those types of wetlands, we
recommend the maximum level of protection be afforded; and recommend that the
new policy framework does not permit the mitigation hierarchy to be applied in those
cases.
A mitigation/compensation hierarchy should only be considered for the replacement of
marginal (function impaired) habitats and should not undermine the protections in
place for highly functional and potentially irreplaceable habitats.
Beyond policy-based approaches, the other critical key activities that should be
employed to achieve no net loss are expanded education and outreach programs
targeted to private landowners and the general public to raise awareness and
appreciation of wetland benefits, as well as targeted land securement. For wetlands of
the highest ecological value that are seriously threatened by development or other
human activities, land securement may be the best (or only) way to afford maximum,
long-term protection to the wetland and its ecological functions.
However, while these other approaches can be important tools in the toolbox, without
significant policy change, they would in no way have the impact needed to reverse the
trend of wetland loss.

b. What tools (e.g. policy) could be used to implement approaches to achieve no net
loss?
In order to effectively and efficiently implement a mitigation/compensation hierarchy,
clear guidance will be needed for proponents, regulatory agencies, and compensation or
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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
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offset providers. These tools and especially those dealing with compensation should be
developed by government through consultation with key stakeholders. Specific tools
will be required to address:
Standards or principles to be applied by proponents to ensure adherence to the
mitigation hierarchy e.g. to demonstrate that all reasonable efforts have been
made (and documented) to first avoid wetland impacts and, then to minimize
wetland impacts, before compensation can be considered as an option (as a
last resort).
Technical guidance for regulators and offset providers on the design and
management of offset projects, including guidance for:
o Limits to offsetting, i.e. criteria for a type of wetland and/or type of
impact that cannot be effectively offset
o Establishing what constitutes an appropriate offset e.g. equivalency
between the impact and the offset, use of offset ratios, etc.
o Duration of offsets
o Proximity of the offset site to the impacted site
o Administration and oversight
NB. For a thorough summary of how other jurisdictions have addressed these
issues in their policies, we would recommend the reader review the 2015 report
by David Poulton for Ontario Nature called Key Issues in Biodiversity Offset Law
and Policy: A Comparison of Six Jurisdictions.
We recommend that strong consideration be given to a market-based benefits exchange
model. This mechanism to match offset seekers with offset providers has been
successfully implemented in other jurisdictions; and has been piloted by the Ministry of
Natural Resources and Forestry under the Endangered Species Act (the Species at Risk
Benefits Exchange).
We believe that the most effective way to achieve compensation for wetland impact,
through a mitigation/hierarchy sequence is via wetland restoration, wherever feasible.
While other wetland conservation techniques may be necessitated in certain
circumstances (such as wetland enhancement or creation or wetland outreach
programs), wetland restoration has been proven to be the most reliable means of
compensating for lost wetland functions and services.
Through its operations in Atlantic Canada and Alberta and more recently in Ontario,
DUC has gained valuable hands on experience (for over 10 years) as the delivery agent
for wetland and upland habitat compensation projects. In those jurisdictions, we work
closely with proponents to design, construct and manage appropriate compensation
projects that meet or exceed the requirements of provincial policy and regulations. We
look forward to discussing with government how DUC can best help to implement a
mitigation/compensation hierarchy including habitat compensation projects under a
new policy framework for Ontario.

c. What might the role of government, partners, private landowners and others be if no
net loss approaches are implemented?
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Once a mitigation/compensation hierarchy is established, the primary role for

government should be the creation of guidance tools (as described in more detail above
in response to the previous question) to enable effective implementation of a no net
loss approach. We strongly recommend that these tools be developed in close
collaboration with conservation partners like DUC, Conservation Ontario and others
with expertise in various aspects of wetland conservation (i.e. protection, securement,
restoration, management and research), as well as industry participants to ensure
solutions that support improved biodiversity as well as economic interests.
The government should also implement expanded education and outreach programs
targeted to private landowners and the general public to raise awareness and
appreciation of wetland benefits, as well as targeted land securement.
d. Should no net loss approaches be applied uniformly across Ontario? Or, only where
the risk of wetland loss is greatest?
Ducks Unlimited Canada recommends that implementation of a mitigation/compensation
hierarchy to achieve no let loss should be applied across Ontario, wherever wetlands are at
risk, but in a way that allows flexibility in implementation in different ecoregions.
Given that the risk of future loss and the amount of historical wetland loss is highest in
southern Ontario (i.e. the Mixedwood Plains Ecozone), we recommend that the government
prioritize implementation of the mitigation/compensation hierarchy in southern Ontario
(e.g. development of the necessary guidance and other tools).
In the Ontario Shield and Hudson Bay Lowlands Ecozones, the extent of wetland
loss/degradation is far less by comparison and there is a much higher prevalence of
peatlands for which compensation is not likely an ecologically or economically feasible
option. In those cases, other wetland conservation mechanisms or techniques may be
required.
The lessons learned in Southern Ontario where a majority of wetlands have already been
lost should inform any strategy for Northern Ontario to ensure a sustainable Northern
Ontario.
7. Do you have any additional suggestions for improving wetland conservation?
References in the discussion paper suggest that implementation of the proposed strategic plan will
occur incrementally over 15 years. However, its not clear from the discussion paper if the
government is also considering a 15 year timeframe to achieve the goal of stopping the net loss of
wetlands across the Province. If so, this timeframe is of concern. It falls short of the governments
commitment in 2014 to reverse wetland loss (a more ambitious goal than no net loss) by 2025 i.e. in
10 years. We believe a 15 year timeframe to achieve no net loss is too long, and will result in further
wetland loss over that time period. We believe 5 to 10 years would be a more appropriate
timeframe, particularly given that the rate of wetland loss in southern Ontario has apparently been
reduced in the 2000s, based on findings on the 2015 State of Biodiversity Report.
And, as noted previously, there is very strong, science-based evidence to support much greater
investment by government in Ontarios wetlands. In particular, investing in wetlands and other
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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
Tele: (705) 721-4444 Fax: (705) 721-4999 du_barrie@ducks.ca

natural infrastructure should be a central plank in the governments historic infrastructure

investment, planned over the next 10 years, in order to realize the full economic and environmental
value of Ontarios wetlands.
Moving forward, the province may wish to consider drawing upon the collective expertise of a
variety of stakeholders and establish a task force to consider the input received on the wetland
conservation discussion paper and formulate recommendations for next steps. A task force may play
a further role in formulating implementation tools and details, should the government decide to
proceed with a no net loss policy including a mitigation hierarchy.
To summarize, DUC supports the development of a strategic plan for Ontarios wetlands that speaks to
the need for stronger policy, effective partnerships, and improved knowledge. However, we strongly
recommend that the first priority in order to reverse wetland loss should be the development of an
overarching comprehensive wetland policy. Combined with large-scale wetland restoration, an
overarching policy that includes the mitigation hierarchy will put Ontario on a clear path to reversing
wetland loss; and ultimately achieving a net gain in wetlands and their benefits. The ultimate success of
a new policy and strategic plan for Ontarios wetlands will largely depend on the allocation of
appropriate resources by government, and collaboration with key partners and other stakeholders.
Thank you for the opportunity to provide our feedback and we look forward to supporting this
important initiative as it moves forward. Should you have any questions, please do not hesitate to
contact myself, Lynette Mader at l_mader@ducks.ca (705) 721-4444 Ext. 235, or Kevin Rich at
k_rich@ducks.ca or (705) 721-4444 Ext. 250.
Yours sincerely,

Lynette Mader
Manager of Provincial Operations Ontario
Ducks Unlimited Canada

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740 Huronia Road, Unit 1, Barrie, Ontario L4N 6C6
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