The St. Clair Region…

ERO number

013-4143

Comment ID

22862

Commenting on behalf of

St. Clair Region Conservation Authority

Comment status

Comment approved More about comment statuses

Comment

The St. Clair Region Conservation Authority is located in southwestern Ontario and includes the Sydenham River watershed and smaller watersheds draining directly into southern Lake Huron, the St. Clair River and northeastern Lake St. Clair. Our position in the Carolinian Life Zone means we have a high percentage of Ontario’s species at risk. This area also has a highly modified landscape with limited protected area, so it is essential to maintain and protect existing natural heritage features and the species at risk that inhabit them. All species, including species at risk, depend on functioning, resilient ecosystems to survive. The primary cause in most species’ decline in the province is due to habitat loss and degradation. The ecosystems which provide habitat to all of our species provide numerous irreplaceable benefits such as air and water purification, soil stabilization, flood prevention and climate change mitigation.

SCRCA supports the Ontario government’s reaffirmation of “its commitment to protecting species at risk and their habitats” (Ontario government’s January 18, 2019 press release, https://news.ontario.ca/ene/en/2019/01/ontario-taking-steps-to-improve-…) and we look forward to a clear conservation-based mandate for the ministry and increased communications and resources for landowners with respect to species at risk.

SCRCA supports the application of the precautionary principle to the Endangered Species Act (ESA). As noted in the ESA R.S.O. 2007 preamble: “lack of full scientific certainty should not be used as a reason for postponing measures to avoid or minimize such a threat.” We are in support of science-based assessments of the current status of species, and proposed actions to assist with their recovery. While all of the desired information may not be immediately available for all species, delays in listing species and initiating recovery actions will only result in further imperilment of the species. Once more information becomes available, the ranking of species can be changed, or removed from the SAR list altogether.

The government should increase support to SCRCA to undertake activities to protect and recover SAR through funding, agreements, permits (including conditions) and advisory services. SCRCA is uniquely positioned to help support the goals of the Endangered Species Act by implementing actions outlined in Recovery Strategies and Government Response Statements. In many cases, goals and objectives of SCRCA’s existing programs and expertise align well with priority actions identified in Government Response statements. As watershed-based resource managers, SCRCA staff are able to contribute local watershed expertise in a cost-effective and efficient manner. Since the Authority is organized on a watershed basis, projects sites are always relatively nearby, meaning that travel costs are minimal. SCRCA also leverages funding from private and public sources at all levels of government towards projects. SCRCA owns 1,600 hectares of land and manages over 2,696 hectares. Much of this property, is conservation land containing many Endangered and Threatened species at risk occurrences. In the past, SCRCA’s species recovery actions have been supported through the Species at Risk Stewardship Fund. Increased funding to SCRCA and other on-the-ground partners will have meaningful impacts to the recovery of species at risk in Ontario.

The Provincial Policy Statement dictates that natural heritage systems shall be identified, and that the diversity, connectivity and long-term ecological function and biodiversity of the systems should be maintained, restored or, where possible, improved. Through natural heritage advisory agreements with our 17 member municipalities, SCRCA is supportive of a landscape-based approach for protecting the remaining habitat for species at risk in our watershed. The Province can provide support to municipalities to update their natural heritage mapping and strategies to help retain natural heritage features to support species at risk populations.

The concept of conservation banking has been proposed as a potential strategy for offsetting impacts to species at risk. This should only be considered as an option after steps have been taken to eliminate and minimize potential negative impacts. The province should carefully examine and provide direction on conservation banking, with input from Indigenous communities, municipalities and stakeholders. If it decides to enable conservation banking through law and policy, it must address such issues as governance and oversight, limits to offsetting, equity, transparency, the mitigation sequence, establishing equivalence, monitoring and enforcement.