As an educator and having my…

ERO number

019-6160

Comment ID

72944

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Individual

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Comment

As an educator and having my students conduct a Wetland Evaluation, allows the students to see the broad scope of criteria assessed during an evaluation. The list of ecosystem services that wetlands provide, notably in populated areas, is vast.
With respect to proposed updates to the OWES, I am concerned most regarding 1) approval of a wetland evaluation and 2) elimination of wetland complexes.
1) proposed to be struck from OWES manuals: “Completed evaluations must be forwarded to the biologist/ecologist at the local MNR District or Area office in which the wetland is located. MNR will review and approve the evaluation. A wetland evaluation is not considered to be complete and official until MNR has signed off on the file.“
Leaving the responsibility of wetland evaluation reviews to municipalities will not likely be objective as municipalities are responsible for development. Municipalities most likely will not have individuals knowledgeable enough to make informed decisions regarding review of a wetland evaluation. Furthermore, many wetlands cross municipal boundaries. There will not be an objective “arm’s-length” review.
2) The proposed changes will no longer allow wetlands to be identified as a complex, thus treating each wetland on its own. The following statement from OWES manuals proposed to be struck is self explanatory: “… the short distances between some of the wetlands, and the density of wetlands per unit of areal 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.”