Comments on watercourse…

Comments on watercourse definition
From: “an identifiable depression in which water regularly or continuously flows”

To: “a defined channel having a bed, and banks or sides.”

Thoughts on what a definition of a watercourse should include: There should be mention of water and fluvial processes in the definition of a watercourse, some important watercourse features are ephemeral, so the reference to the ephemeral nature of some watercourses should be kept. Important to include the drainage function in a definition of a watercourse.

Comments on Wetlands and the reduction of the area of concern to 30 m around all wetlands (as opposed to 120 m around PSW/Unevaluated Wetlands)

There is an increased potential for problems and negative impacts to wetlands with removing the 120 m area of concern when it comes to larger and potentially higher impact projects in proximity to provincially significant or otherwise potentially sensitive wetlands. It is often the case already that projects with a limited potential for impact to a wetland feature can have study and permit submission requirements scaled back to the risk associated with the project (i.e. not every project within 120 m of a PSW requires an EIS).
120 m is the number used in to define adjacent lands for most significant natural heritage features in the Ontario Natural Heritage Reference Manual, although it seems that several references cited in this document indicate that 120 m may not be a sufficient buffer size to protect wetlands from impacts. Whatever size of distance is used to define the adjacent lands next to a significant feature should be based on the best available information on effectiveness of buffers.