The proposed changes that allow re-evaluation of wetland complexes as single wetlands defies wetland science and is clearly done here to make it easier to undervalue and hence develop wetlands. The importance of diversified wetland complexes to wildlife (including sensitive, threatened, and endangered wildlife), to flood abatement, water quality improvement, biodiversity enhancement, carbon management, and aquifer recharge are all well documented. Milton Weller wrote about this as long ago as 1988 (see attached). We know they are connected by groundwater, even at a distance, and that wildlife use the entire complexes, not individual wetlands. The benefits within a complex are not additive but interactive and synergistic, meaning that they can't be meaninfully reduced to what each smaller wetland within the complex would contribute on its own. Allowing the reevaluation of individual wetlands will result in underestimating their overall contributions to wildlife and to society. I urge you to reconsider this change as it is not supported by long-standing wetland science.
Submitted October 27, 2022 12:17 PM