Review Comments on proposed…

Review Comments on proposed update to OWES

Pages 4 & 5– evaluator doesn’t have to consult local MNRF district to ensure that the correct manual is used in situations where the Ecoregion is uncertain – WRONG MANUAL COULD BE USED IF MNRF CONSULTATION IS ELIMINATED

Page 4 - eliminates the need to gather more information if the evaluation is determined to be incomplete, before making decisions about the types of land uses in the vicinity of the wetland – DECISIONS COULD BE MADE BASED ON INCOMPLETE INFORMATION

Page 5 – eliminates mention of the use of wetland evaluations for planning by entities other than municipalities (i.e., by the province in land use planning, by conservation authorities, and by MNRF) - USE OF WETLAND EVALUATIONS FOR PLANNING BY MUNICIPALITIES IS EMPHASIZED, TO THE EXCLUSION OF OTHER ENTITIES

Page 6 – mention is removed about consultation with MNRF about interpretation of the evaluation system, leaving evaluations entirely up to the evaluator – WITHOUT MNRF ASSISTANCE WITH INTERPRETATION, EVALUATIONS MAY BE DONE INCORRECTLY

Pages 6 & 7 – proposed wording allows individual wetland units and boundaries to be re-evaluated independent of the overall wetland and other wetland units – THIS APPROACH IGNORES THE RELATIONSHIP/INTERDEPENDENCE OF WETLAND UNITS IN A WETLAND COMPLEX, A SHORTCUT THAT CAN LEAD TO POOR DECISIONS

Pages 7 & 8 – mention is removed of review and approval of an evaluation by MNRF for the evaluation to be considered “complete”; instead completeness merely means receipt by a decision maker addressing a land use planning and development or resource management matter – THE DECISION MAKER MAY HAVE NO QUALIFICATIONS TO DETERMINE COMPLETENESS OF THE WETLAND EVALUATION - LACK OF REVIEW AND APPROVAL BY MNRF IS INTRODUCING THE OPPORTUNITY FOR INCOMPLETENESS AND INCONSISTENCY IN EVALUATIONS, THEREFORE LEADING TO POOR DECISION MAKING

Pages 9 – 11 – the description of contents of a complete wetland evaluation file has been removed – WITHOUT SUCH GUIDANCE ABOUT CONTENTS OF A WETLAND EVALUATION FILE, THERE IS INCREASED LIKELIHOOD THAT FILES WILL BE INCOMPLETE AND WETLAND EVALUATIONS WILL BE DEFICIENT

Pages 11 – 13 – much guidance about sources of information has been removed – LACK OF GUIDANCE ABOUT INFORMATION SOURCES WILL LIKELY LEAD TO DEFICIENT EVALUATIONS

Page 14 – the mention is removed of undertaking an evaluation using other information when landowner permission for access to the property is denied – THE ABSENCE OF SUCH GUIDANCE MAY LEAD TO THE FALSE CONCLUSION THAT AN EVALUATION OF THE WETLAND IS IMPOSSIBLE, RESULTING IN DECISIONS BEING MADE WITHOUT CONSIDERATION OF THE WETLAND

Page 18 – the deletion of approval of revisions of the MNRF is another example of the removal of the checking function of MRNF, similarly the deletion of consultation with MNRF in cases of evaluator uncertainty – CONSULTATION, REVIEW AND APPROVAL BY MNRF IS IMPORTANT FOR CORRECTNESS AND COMPLETENESS

Page 21 – another deletion of MNRF involvement, in this case the setting of the final upriver and downriver limits of wetlands – MNRF INVOLVEMENT IS IMPORTANT FOR CONSISTENCY AND CORRECTNESS

Page 24-25 – much guidance about the wetland data record has been deleted – THIS GUIDANCE DOES NOT APPEAR ELSEWHERE, THEREFORE REPRESENTING A DEFICIENCY

Page 26-28 – much information about wetland complexes has been deleted – AGAIN, THIS INFORMATION DOES NOT APPEAR ELSEWHERE, REPRESENTING THE LOSS OF USEFUL INFORMATION

Page 41 (2 places) – deletion of mentioning to MNRF as a source of information – MMRF IS AGAIN BEING CUT OUT OF THE PICTURE, WHICH WILL RESULT IN DIMINISHED QUALITY OF THE EVALUATION

Page 42–48, 51 – additional deletions of references to MNRF – EXCLUSION OF MNRF INVOLVEMENT IS NOT GOOD

Page 52 – total deletion of section on Reproductive Habitat for Endangered or Threatened Species – HOW CAN ELIMINATION OF THIS BE JUSTIFIED?

Page 52 – total deletion of section on Migration, Feeding or Hibernation Habitat for Endangered or Threatened Species – AGAIN, HOW CAN ELIMINATION OF THIS BE JUSTIFIED?

Pages 53-60, 62, 64 – more deleted references to MNRF – DISAGREE STRONGLY TO MNRF EXCLUSION

Page 63 – total deletion of sections on Locally Important Wetlands and Planning Boundary – HOW CAN THIS BE JUSTIFIED, GIVEN THAT THIS HAS TO-DATE BEEN SUFFICIENTLY IMPORTANT TO BE RETAINED?