Comments on the 10 Year…

Comments on the 10 Year Review of Ontario’s Endangered Species Act EBR Registry Number 013-4143

Landscape Focus
• I think that a landscape approach could work for species that make use of large areas. However, you better think it through very carefully as to what that looks like in terms of on the ground implementation. For example, the approach to habitat management for woodland caribou appears to have adversely affected marten, moose and wolverine populations since very large clearcuts are promoted. You had better watch that your efforts for one species don’t cause other species to end up on a threatened or endangered list.
• You need to recognize, in a landscape approach, where your prescription for the target species may not work. In other words, it isn’t a one size fits all prescription. Again, caribou are a fine example of this. In the Trout Lake Forest Unit a large percentage of the unit is more conducive to the production of moose yet we have applied habitat management prescriptions for woodland caribou. The result is that you have degraded moose habitat and this has resulted in a significant population decline. We are also seeing a significant impact on furbearer populations all in the name of woodland caribou. This in turn has had significant social, recreational and economic impacts on indigenous peoples, local residents and the tourism industry. We seem to get tunnel vision and forget that these other species are valuable ecosystem components!
• We need to recognize the influence of climate change on the outcome that we would like to achieve in the future. If the future outlook for a portion of the landscape that you want to manage for a species is not positive don’t implement management actions that a/ ultimately won’t work and b/ have adverse effects on other species.

Listing Process and Protections for Species at Risk
• In my opinion COSSARO and SARPAC do not function effectively. I would submit that their recommendations are based more on personal opinion/agendas and political expediency than on scientific evidence. A very real example of this is the case of wolves in Southern Ontario.
• The recommendations made by COSSARO/SARPAC do not instill confidence that decisions are science based. If there needs to be an advisory body then it should be concerned with the scientific basis for recommendations and not politics. This is an opinion held by myself and a large number of other members of the public.
• Is a review body needed to make recommendations to government? I think that one is probably needed but let’s review and revise the membership and mandate so that a/ decisions are science based and b/ the process of decision making is much more transparent. At this point COSSARO/SARPAC doesn’t appear to have to make public any of the discussions that they undertook to get to a recommendation or to describe the science that was considered. Again, this doesn’t add to public confidence in COSSARO/SARPAC or the process to place species are on the various protection lists.
• If we have an independent body to make recommendations to government then the public needs to be able to see the science that was used in making a recommendation, how it was interpreted and, the minutes of discussions by that body. In addition, the public needs to have the ability to comment on a recommendation and there needs to be a dispute resolution mechanism.
• If we want public review and input and a dispute resolution process is implemented then we need to increase the timeframe before a species is added to the Species at Risk list.

Species Recovery Policies and Habitat Regulations
• The time limit of 9 months to develop a response statement is too short in my opinion. Perhaps for some species this might work but probably not for all species. If you try to jam, what needs to be very thoughtful work, into a relative short timeframe you won’t get a good product. There needs to be more time for public review and input.
• The recovery strategies that have prepared to date for some species are problematic in my opinion. It would appear to me that these strategies don’t adequately consider the impacts to other species or to social and economic values. For example, the habitat management activities related to caribou have adversely affected moose, American marten and wolverine habitat.
• I also submit that recovery strategies create “tunnel vision” in government so that the species in question is all that they see. Again, a good example is woodland caribou. In forest management planning all we hear about is the habitat needs for woodland caribou and why we can’t do something innovative for other species. When you mention other species considerations the response is caribou are the priority and the other species will receive “consideration”. I have yet to hear and understand what “will receive consideration” means.
• Lastly, if you want to garner public support for managing some of the species that are threatened or endangered then don’t establish management actions that appear to trade one species off for another.
• I am also concerned about the review process. Firstly, I don’t think that a robust review or monitoring process is in place. Secondly, the impacts of management actions intended for an endangered species on other species doesn’t seem to be considered important. If you want to look at impacts on other species beside the target species then monitoring that begins within 5 years would seem appropriate.