Pg. 4 - Removed verbiage…

Pg. 4 - Removed verbiage around the fact that data gaps are present in wetland evaluation files (ie. Presence of rare species and hydrological functions may be missing). HOWEVER continues to state the following: The application of this system provides knowledge of the different kinds of wetland values, which is then available for examination and review by any interested person, agency or group. This seems to imply that the wetland evaluation file may substitute for site specific study for development/permitting?

Pg. 4 - Previous verbiage in OWES indicated that PSWs are protected under the PPS, this has been struck out of the revised version implying that PSWs are no longer protected under the PPS?

Pg. 7 - Complete evaluations must be forwarded to the biologist/ecologist at the local MNR District or Area office in which the wetland is located. This has been scratched out. It is unclear who the evaluator is to submit their evaluation.

Pg. 8 - New terminology added: 'Complete Evaluation' - 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 or resource management matter. It is unclear who the 'decision maker' is and who will ensure evaluations are done by qualified professionals following OWES protocols as the MNRF has been struck from the document. Where are the evaluations to be submitted and who does the updating (e.g. mapping updates for boundary revisions and status on the wetland). Who is to oversee this repository?

Pg. 9 - Agricultural usage is more clear: planting of crops or tillage should no longer be considered wetland.

Pg. 11 - Sources of information for background/desktop review of wetlands have been removed and significantly reduced, general intent remains the same and qualified evaluators will be familiar with these methods and information sources. Consistency of background desktop review for evaluators will be assumed.

Pg. 14 - Landowner Notification and Permission - Clearly identifies that landowner permission is required prior to attending a site, however implies that wetland evaluations may be completed without permission to access as it is 'a courtesy to notify landowners that a wetland evaluations is being undertaken for a wetland located on their property'.

Pg. 14 - Wetland evaluations required to be completed at an appropriate time of year - not defined in either the previous version or updated version of OWES. Recommend that appropriate timing be laid out (eg. During the growing season) to allow for greater consistency and avoid back and forth for evaluations completed during inappropriate times.

Pg. 20 - 'slough wetlands' are included and described as areas comprising very closely spaced ponds/pools (e.g. within 30 m from each other) interspersed with small pockets of upland forest. These areas are to be evaluated as one wetland under OWES. This section is included in Wetland Edges Bordering on Lakes and Rivers - should be it's own section or more appropriately in the section Wetlands Bordering on Upland Forest. Glad to see that slough wetlands are included.

Pg. 21 - Wetlands on Ontario's Major Lakes and Rivers - resistance to complexing poses problems for these units: The 2 m depth contour (at low water) is to be used to define the deep water boundary of these wetlands (see exceptions above). If the evaluator encounters underwater shoals or knolls rising like islands from deeper water and the tops of these are less than 2 m from the surface, they should be included in the wetland map and the wetland with which they are associated is to be defined as one wetland a complex(a complex removed from and replaced by one wetland) and evaluated as such. Additional clarity should be provided - is the area between these knolls considered part of the wetland or not similar to mosaic/slough wetlands described earlier in the document.

Pg. 22 - Wetland mapping is required to be consistent with LIO, however, as MNRF is no longer approval authority for wetland mapping updates/evaluation changes guidance is required to understand the process for which mapping updates will be incorporated. Who is authorized to approve a change and submit to LIO?

Pg. 26 - The current OWES document highlights the importance of Wetland Complexes ...Many areas of Ontario contain closely spaced wetlands that vary in size from a fraction of a hectare to several hundred hectares. The topography of the landscape in which these wetlands occur, the short distances between some of the wetlands, and the density of wetlands per unit of area landscape may be so complex that delineation of the wetland units into individually recognized wetlands would not be an ecologically or functionally sound process. Such groupings of wetlands are referred to as “wetland complexes.” Much of the wildlife in the area of the complex is variously dependent upon the presence of the entire complex of wetlands, with each wetland unit contributing to the whole. Now the proposed OWES has completely omitted complexing. This is critical because as previously stated some of the wetlands, and the density of wetlands per unit of area landscape may be so complex that delineation of the wetland units into individually recognized wetlands would NOT be an ecologically or functionally sound process.

Pg. 36 - OWES continues to be ambiguous regarding size of mappable units. 2 ha typically smallest to be evaluated, 0.5 ha smallest mappable vegetation unit - both caveated with that rare flora and fauna may result in significance for smaller polygons. This should be made abundantly clear that limited size does not preclude the potential significance of a wetland and that even small wetlands require study to determine significance.

Pg. 37 - evaluators were required to fill out the same forms but now the forms are just a guide -> Appendix 4 provides templates that will assist in organizing field data. This leaves much to interpretation and takes away a standardized approach to how the information is being presented.

Pg. 42 - If a wetland is used by Aboriginal hunters only, there is no longer a bonus score for Aboriginal value in Section 2.8.1. This gives the impression that cultural importance by first nations are not given the appropriate consideration.

Pg. 49 - Location of species of conservation concern should not be incorporated into publicly accessible versions of the wetland evaluation doc. How is this to be realized if wetland changes are submitted to an unknown entity through a planning process in which supporting documentation becomes part of the public record? Previously MNRF administered Element Occurrence data AND wetland evaluation files, now an unknown middle entity will approve wetland evaluations.

Pg. 62 - The review/approval function of wetland evaluations by the MNRF has been scratched out. Again, unclear who will be reviewing evaluation files.

Pg. 64 - Appendix 10 formerly provided an authoritative list of wetland species to be utilized to apply the 50% vegetation rule when delineating wetland boundaries. This has been revised to be a guideline, this is likely to result in confusion and delays when delineating wetlands due to differences in professional opinion in the absence of an authoritative list.

Pg. 64 - Wetland Plant List may be updated from time to time and these updates will be available on a website. No further detail is provided as to which Ministry, organization etc is responsible for updating the plant list.