Additional Information Request # 9 Potential Effects on Rare Plants Related Comments: CEAR #544 (Ontario Ministry of Natural Resources) In its response to IR 15.1, SCI states that the Project would result in regionally or locally significant impacts to three rare plant species (Alga Pondweed, Oakes' Pondweed, and Northern St. Johnswort) found in the small headwater lakes near the center of the project site in the absence of mitigation. In addition, loss of the Broad-lipped Twayblade, which inhabits moist sites along streams and lake shores, is assessed to be locally significant. SCI concludes that no significant residual effects will occur based on the ability to mitigate and commits to: Conducting further inventory of nearby water bodies and transplanting Alga Pondweed and Oakes' Pondweed from existing habitat to appropriate small lakes nearby; and Minimizing disturbance within the Project Footprint. Based on the information provided by SCI, the water body where these species exist will be permanently lost by construction of the PSMF. In the Ontario Ministry of Natural Resources’ view the suggestion that impacts can be mitigated by minimizing the footprint is not valid. In addition, SCI has not provided evidence to indicate that similar, suitable habitat exists nearby for the transplantation of rare plants nor is there an assessment of the likelihood of success in establishing new plant populations. In the Ontario Ministry of Natural Resources’ view, without further evidence to indicate that the proposed mitigation measures will have a good chance of success, it seems very possible that the Project will result in the permanent elimination of one occurrence of Alga Pondweed and two occurrences of Oakes’ Pondweed. Specify the required attributes and availability of potential transplantation locations to achieve successful transplantation, survival and stability of the rare plant communities. Identify and reference instances in similar ecological systems where this type of mitigation has been applied successfully in order to support the conclusion that the proposed mitigation would be successful. SCI Response: A literature review (e.g. Cullina 2000, Dick et al 2013, Payne 1992, Smart and Dick 1999) and web-based search on transplanting and propagation of these species was conducted. When species-specific or habitat-specific information was lacking, information from similar species or habitats was summarized. Pondweed Biology and Transplanting No literature on transplanting Alga Pondweed (Potamogeton confervoides) or Oakes’ Pondweed (P. oakesianus) was found. However, there is an abundance of literature on the cultivation, and transplantation of other species of Potamogeton (e.g. Beckett et al. 1999, Catling and Dobson 1985, Dick et al. 2013, Kujawski and Thompson 2000, Lauridsen et al, 2003, Payne 1992, Riis et al. 2009, Smart and Dick 1999, Webb et al. 2012, Wilkinson, et al. 1999). Pondweeds (Potamogeton sp.) are perennial aquatic plants that complete their lifecycle submerged beneath the surface of lakes, ponds, and stream. Pondweeds reproduce by stem fragments, rhizomes, turions (overwintering buds), and by seed (Haynes and Hellquist 2000). Alga Pondweed (S2) produces seeds in July and turions in late summer (Penskar 2009). It has well developed rhizomes (Haynes and Hellquist 2000) and is apparently also dispersed by fragments of stems and rhizomes carried by the water or by waterfowl (Penskar 2009). Oakes’ Pondweed (S4, regional status) reproduces from seeds, rhizomes, and stem fragments, but lacks turions (Haynes and Hellquist 2000). Both pondweed species prefer acidic ponds and lakes with sedimentary organic substrates (Haynes and Hellquist 2000, Penskar 2009, Crow and Hellquist 2000). In New England, Hellquist (1980) determined - the mean alkalinity of water in which Alga Pondweed occurred to be 4.2 mg HCO3 /L. Oakes’ Pondweed - was found in waters with a mean alkalinity of 8.8 mg HCO3 /L). The lakes in the Stillwater Local Study Area where these species were identified are small, with bedrock shores and floating fen mat (W-type 14; Ecosite 45), and relatively isolated (i.e. not connected to other lakes by well-developed streams). Waters were tea-coloured (stained by dissolved organic material) (Figure 1). Case Histories We found no documented cases of transplanting Alga Pondweed or Oakes’ Pondweed, however these species share similar methods of reproduction with other pondweeds and techniques should be transferrable between species. Beckett et al. (1999) and Wilkinson et al. (1999) successfully transplanted Richardson’s Pondweed near Elliot Lake and Sudbury, Ontario. Rooted stem fragments of some pondweeds are used in large-scale restoration project in the United States (Kujawksi and Thompson 2000). Riis et al. (2009) describe a successful method of transplanting aquatic macrophytes, including a species of Potamogeton, into streams, and offer recommendations. Potential Habitat Forest Resource Inventory mapping shows 236 water polygons totalling 605 ha in the Local Study Area (5 km radius around the project footprint). These include 45 or more small lakes and ponds in the bedrock-controlled uplands north and west of Bamoos Lake ( Figure 2). These lakes occur on a landscape with similar bedrock and soils, similar post-glacial history, and physical environment to that of the Stillwater site. These lakes are considered likely to be potentially suitable receptor sites for transplanting the two pondweed species. To assess the suitability of receptor sites, several attributes will be compared with those from the Stillwater site where the species originated. These attributes include: Associated vegetation community dominants: Sites with a similar assemblage of dominant submergent and floating vascular plant species, including Alga or Oakes’ Pondweed, will be sought. Water pH and/or alkalinity: Hellquist (1980) measured alkalinity in lake and stream waters for New England and identified suitable thresholds (mg HCO3-/ L) for both Alga and Oakes’ Pondweed. Suitable receptor sites will most closely match the pH and alkalinity results from the site of origin, and will fall within the range accepted by Hellquist (1980). Substrate: Sites with a similar substrate to the site of origin will be sought. Proposed Technique Plant propagules including rhizomes, stem fragments, turions, and seeds (depending on the availability) will be collected in late summer from the known sites for the two species ( Figure 2). In Potamogeton, even fragments of plants can be used successfully in recruitment, since they readily root from nodes (Hengst 2007, Kujawski and Thompson 2000). Ideally, large amounts of material will be collected if available. Plant material will be kept moist and cool and transported immediately (< 2 hours) to the receptor lake. Some of the propagules will be placed in between layers of wire mesh (Wilkinson et al. 1999) and placed in 50 to 100 cm of water on sedimentary organic substrate. Planting sites will be sheltered from wave action. Other propagules, especially stem fragments including turions (if found), will be distributed on the surface of the lake. In experimental conditions, Hengst (2007) found that 45-60% of fragmented stems of P. perfoliatus successfully propagated when distributed on the surface of an aquarium tank. Both pondweed species will be transplanted to about five lakes in this manner, to increase chances of success. Transplant sites will be recorded with a GPS reading and written description in order to help relocate them for monitoring. Northern St. Johnswort (Hypericum mutilum) Northern St. Johnswort (S5, regional status) is a perennial plant that reproduces by both seed and rhizomes (Gillett and Robson 1981). It produces numerous small seeds (hundreds / plant) which can remain viable in the soil seed bank for several years (up to 50 years in some species of Hypericum). Habitat typically consists of moist sandy or mucky shores (Michigan Flora On-Line 2011). Case Histories No case histories of transplanting this plant have apparently been documented. Northern St. Johnswort can be propagated by sprigs and seed and is occasionally available from commercial nurseries (see http://www.gardenguides.com/taxonomy/dwarf-st-johnswort-hypericum-mutilum/). Other species of Hypericum are easily established by seed, cuttings, or rhizomes (e.g. Zouhar 2004). Potential Habitat Forest Resource Inventory mapping shows 236 water polygons totalling 605 ha in the Local Study Area (5 km radius around the project footprint). These include 45 or more small lakes and ponds in the bedrock-controlled uplands north and west of Bamoos Lake (Figure 2). These lakes occur on a landscape with similar bedrock and soils, similar post-glacial history, and physical environment to that of the Stillwater site. Shorelines of these lakes are considered likely to be suitable receptor sites for transplanting Northern St. Johnswort. Shorelines often host a unique suite of species that are able to persist under spring high water, and emerge to flower when water is low in the late summer and autumn (e.g. list any other species from site, if possible). Receptor sites will be sought with a similar suite of species as the original site. Other habitat characteristics that will be sought include: Substrate type – soil particle size (coarse/fine sand, silt, etc.) pH Proposed Technique Whole plants and roots, including rhizomes where possible, will be dug up in late summer from the known site for the species. Moist sandy soil from the site will