The minimum prescribed…

The minimum prescribed buffers listed in Table 3-2 are concerning as these amounts have been predetermined without an Environmental Impact Study or other detailed analysis. Context and the attributes of the environmental feature are important consideration when assessing the buffer needed for the feature. This section should be reviewed and revised to read "recommended buffers to be further refined by study where applicable".

Section 3.1.9.5.6 b) i) and ii) state that if the canopy coverage in a wetland is greater than 25% then the other woodland policies apply and in the case of 60% canopy coverage, the significant woodland policies apply. Again, canopy coverage is a attribute of a feature that should be determined through a detailed EIS or related study and not through an aerial photo or high level mapping.

The policies appear to be overprotective of unstudied features and do not provide an adequate opportunity for assessment and reconsideration. These sections, among others should be reviewed and revised.