Comments received >

September 19, 2006 - R.F. Maher, Manager, Provincial Operations (Ontario), Ducks Unlimited Canada

Dear Canadian Section Secretary,

Please consider this letter as Ducks Unlimited Canada support for candidate regulation Plan B+ as referenced in the Final Report by the International Lake Ontario-St. Lawrence River Study Board.

Ducks Unlimited Canada is an international, private, non-profit wetland and waterfowl conservation organization that has been focusing on Great Lake coastal wetlands in the provinces of Ontario and Quebec since the mid 1970's. Since this time we have secured and restored 70 wetlands representing 10,947 hectares of wetland habitat along the shoreline of the Great Lake basin and an ongoing investment of just over $16.3M. Specifically along the coast of Lake Ontario and upper portion of the St. Lawrence River, we have worked with federal, provincial and municipal governments, community groups, and private landowners to protect and restore 62 wetlands totaling over 10,000 hectares of wetland habitat. Common to all these wetland projects is the fact that they are all influenced to some extent by Great Lake water levels just as are the unmanaged coastal wetlands.

These wetlands are of continental importance to waterfowl, and a diversity of migratory birds, species at risk and other wetland dependent wildlife species. As such, the loss or impairment of these wetlands has significant impact not just in Canada and the United States, but also for other countries of the world that are the recipients of species that pass through the Great Lake basin for part of their life cycle.

We concur with the report's premise that a more natural water level regime would be beneficial for the environment, especially for wetlands and the wildlife species that they support. A wide variation in water levels and the subsequent known response of wetland plants to water level fluctuations is critical to the composition and structure of healthy wetland habitats. Plan B+ represents an important step towards restoring a more natural hydrology to Lake Ontario with its natural timing of seasonal rise and falls. Incorporating periodic low and high water events into the plan is imperative for wetland rejuvenation and promotes wetland plant diversity. Low water events fostered only by Plan B+ are especially critical in the rejuvenation of emergent aquatic vegetation from seed banks, the enhancement of meadow marsh habitats and promoting diversity in existing vegetation monocultures.

The fact that Plan B+, in addition to its strong environmental performance positively affecting continental wildlife populations, provides net benefits to hydro electric generation and commercial navigation makes this candidate regulation scenario the most desirable option. Even though Plan B+ failed to be the strongest performer for recreational boaters, the final report indicates that they came out in support of the candidate plan which thereby increases its merits. Furthermore, Ducks Unlimited Canada's knowledge of the broader societal benefits that these wetland habitats afford through our work with private landowners and various communities interested in wetlands would indicate strong public support for adopting Plan B+ from a public interest perspective.

Ducks Unlimited Canada appreciates the opportunity to provide our support for candidate regulation Plan B+.

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