Please revisit the…

Please revisit the regressive changes proposed to the OWES. Ideally, keep the OWES as it is - the system is not broken, don't fix it. Below are my specific comments.

1. Retain the section of the OWES Manuals titled “Wetland Complexes” as well as all references to wetland complexes / complexing.
2. Amend the proposed “Re-evaluation of previously evaluated wetland complexes” subsection to state that re-evaluation of wetland complexes may only occur through a complete re-evaluation of all units in the existing wetland complex, and that the status of a wetland complex (e.g., significant or not) may only change based on a re-evaluation of the complete wetland complex (i.e., all units that were previously evaluated as part of the wetland complex must be re-evaluated at the same time).
3. If the proposed section titled “Wetland Re-evaluations and Mapping Updates” remains in updated OWES manuals, amend the section to ensure that previous wetland evaluations must be considered when undertaking re-evaluations to clearly identify and document where changes have occurred which result in a different cumulative score.
4. Retain section 4.1.2.1 (Reproduction Habitat for an Endangered or Threatened Species) and section 4.1.2.2 (Migration, Feeding or Hibernation Habitat for an Endangered or Threatened Species) in the OWES manuals to signal the high importance of these attributes when evaluating or re-evaluating wetlands. Retain the current evaluation scores for these attributes.
5. Amend the OWES Manual to state that a “wetland evaluation, re-evaluation or mapping update will be considered “complete” once it has been received by a decision maker addressing a land use planning and development or resource management matter, and has been submitted to the Ministry of Natural Resources and Forestry District or Area office in which the wetland is located”.
6. Clarify who a “decision maker addressing a land use planning and development or resource management matter” may be to assist external agencies such as conservation authorities and private landowners with navigating the process of obtaining completed wetland evaluations.
7. Retain the section of Appendix 1 which speaks to “locally significant wetlands” to provide transparency of process for wetland designation and protection for wetlands which do not meet the criteria for a “provincially significant” designation.