Comment on area of focus 1 -…

ERO number

013-4143

Comment ID

23790

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Comment on area of focus 1 - Landscape approaches:
- Species-specific and landscape approaches should go hand in hand when designing ways in managing Species at Risk (SAR). Indeed, landscape approach is an efficient way to design ways in managing SAR, however, since each species is different and have different habitat requirement, species-specific approach should still be the main management approach, while landscape approach should be a supplementary approach in deciding SAR management approach. This is especially important to species that are highly endangered and with a decreasing population trend. Depending mostly on landscape approach as the main way to design SAR management will risk missing important information regarding a SAR's ecological needs.

Comment on AREA OF FOCUS 2 – LISTING PROCESS AND PROTECTIONS FOR SPECIES AT RISK:
- SAR Listing decisions should be based entirely on best-available science from experts and Aboriginal Traditional Knowledge, economical reasons should not be included when listing decisions are made. Immediate actions should be taken to fight species endangerment and extinction. While the listing process is already unnecessarily long, and such long timeline has already shortened the time spent in coming up with effective SAR management approaches, involving businesses and the public will only lengthen and complicate the listing procedure. Eliminating the involvement of businesses in species listing will also eliminate any sort of economical incentive that leads to favouring development over SAR protection. Endangered and threatened species should continue to be protected automatically. Information from COSSARO meetings can be posted online to improve transparency.

Comment on AREA OF FOCUS 3 – SPECIES RECOVERY POLICIES AND HABITAT REGULATIONS:
- As mentioned earlier, fighting species endangerment and extinction requires immediate actions. SAR populations and their habitat conditions should be constantly monitored, and for species that are highly endangered, their population status and recovery progress should be monitored even closely to prevent them from going extinct. The time limit of nine months to develop the Government Response Statement should be shortened, or if not, remain unchanged, and not lengthened. A recovery progress review should be conducted every 3 years.
- A species specific habitat regulation should always be in place for endangered and threatened species. Many species have unique habitat requirement during different life stage. This is especially true for aquatic species. Having general habitat protection will not fully protect species with different life stage requirements. Only through understanding a species' habitat requirement will lead to designing effective management approach to conserving the species.

Comment on AREA OF FOCUS 4 – AUTHORIZATION PROCESSES:
- Human activities highly impact the ecosystems and species population. For example, hunting and fishing directly impacts the population trend of a species, releasing non-native species to an ecosystem may lead to biological invasion and other ecosystem disruption. Human activities that will affect the status and recovery progress of endangered and threatened species should be highly regulated. The government should not see authorization processes as "administrative burdens", it is an act of precaution and to ensure that there is no further endangerment of SAR.

All in all, when it comes to protecting Species at Risk, it is a race to rescue these species that are valuable to Ontario's biodiversity and to the overall global biodiversity. Economic development should not be included in the Endangered Species Act, and it should not affect any Species at Risk listing, protection and recovery strategy decisions. Best-available science and Aboriginal Traditional Knowledge should inform SAR listing and protection decisions. Climate change should also be accounted for when designing SAR management approach.