Comments for sections 4.2.2…

Comments for sections 4.2.2-4.2.5
I believe the Significant Wildlife Habitat (SWH) ecoregion schedules can be a useful way of identifying areas of importance for wildlife, including those that use wetlands. It may be able to identify areas that the MNR and CWS have not already identified. However, there are several issues with the SWH ecoregion schedules that should be addressed before relying on them to score sections 4.2.2-4.2.5.
One issue I have is using some of the fieldwork protocols outlined in the ecoregion schedules to assess the bird-related SWH criteria for several reasons. First off, the SWH ecoregion schedules tells the evaluator to follow the protocols outlined in the Birds and bird habitats: guidelines for windpower projects. https://www.ontario.ca/page/birds-and-bird-habitats-guidelines-windpowe… The guideline relates to windpower projects, not SWH, and does not seem appropriate to use. Second, none of the bird SWH criteria in the ecoregion schedules specifies which protocols in the Birds and bird habitats: guidelines for windpower projects to actually use. The guideline is an assemblage of different protocols, which can make it difficult for the evaluator to know which one to use. This can result in inaccurate results, especially if the evaluator is inexperienced in performing these types of surveys. Third, the timing windows to do surveys in some of the SWH criteria can be too broad to observe the species. This can lead to missing the target species during the surveys. For example, for the landbird migratory stopover areas, the SWH ecoregion schedules 6E and 7E say the surveys can be done starting at the beginning of April. In Southern Ontario, this is not an appropriate time to survey landbirds, since very few species are in Ontario at that time. Surveying then will almost certainly result in the study area coming out as not confirmed for SWH, especially if evaluators only do the bare minimum number of surveys.

All the reasons I state above will result in inconsistency in how the fieldwork is completed.

A second issue with the SWH ecoregion schedules is the ambiguous language used for assessing sites as confirmed SWH. Confirming many of the breeding bird SWH criteria (e.g., section 4.2.3 waterfowl breeding) often requires that evaluators observe “nesting pairs”. As an ornithologist, this is confusing since “nesting pairs” does not state what level of breeding evidence is needed (possible, probable, or confirmed breeding evidence under the Ontario Breeding Bird Atlas https://www.birdsontario.org/breeding-codes/). Most ornithologists rely on these evidence codes to collect data. The ambiguous language in the ecoregion schedules very likely will result in evaluators inconsistently assessing sites for confirmed SWH.

I strongly suggest improving the survey protocols and the ambiguous language in the SWH ecoregion schedules before using them to assess sections 4.2.2-4.2.5 in the OWES manual.

It is also necessary to provide training to evaluators in how to complete and assess SWH assessments for wetlands so there’s consistency.

For section 4.2.5, there is no SWH criterion for raptor stopover habitat. How are surveyors supposed to assess it without a criterion? This change effectively eliminates the ability for evaluators to assess a wetland for raptor stopover habitat. I suggest maintaining the areas that the MNR or CWS has already identified.

I have serious concerns with wetland evaluators now doing these SWH assessments. Wetland evaluators require botanical identification skills amongst others. Now, they also must be able to identify birds too. I know many botanists; very few of them also have strong bird identification skills, let alone have any experience also doing the targeted SWH surveys in the OWES manual. I strongly suggest you also allow surveyors with specialized skills to contribute to the evaluation process.
Also, will wetland evaluators now receive training on how to do SWH assessments as part of their certifications?

Comments for Sections 4.1.2.1-4.1.2.2
I am very concerned about the removal of sections related to threatened or endangered species. What is the justification for doing this? Wetlands that support threatened or endangered species are generally less common in the landscape and would be more significant than those that don’t.