can only be achieved through…

can only be achieved through the strictest interpretations and implementation of the ESA. The ESA alone does not have the necessary tools to properly manage SAR under the myriad conditions and circumstances that exist across the province. There are certain species and pressures where the current application of the ESA has limited/no demonstrable benefit to SAR, but could likely benefit from other non-ESA tools.

Ontario’s forest industry in the Area of Undertaking is an excellent example of a regulated activity with the potential to benefit SAR beyond the traditional application of the ESA. Forestry on Crown land is governed by comprehensive legislation and policies with a focus on biodiversity, ecosystem function, and wildlife/fisheries values. Our forest management system is replete with species inventories, planning, implementation, monitoring, compliance, and auditing processes. Forest management plans under the CFSA already consider SAR values, making the CFSA an ideal implementation mechanism to complement the ESA in the Area of Undertaking. A separate, parallel system under the ESA would be incapable of benefitting SAR to the degree that the existing forest management system has the capacity to do. The inclusion of new caribou direction in the Forest Management Guide for Boreal Landscapes, while imperfect, is proof-of-concept that non-ESA tools are capable of integrating species at risk considerations.

We fully agree with the need to extend the current exemption period to give the government an opportunity to undertake further discussions on the development of a system that provides certainty and direction for both wildlife conservation and the forest sector. However, we believe that an additional two years is an unrealistically short time frame in which to accomplish the ambitious goals outlined in this proposal, specifically the creation of an independent panel of experts tasked with developing a long-term solution to integrating species at risk considerations in Crown forest management. As such, we recommend that the current exemption be extended for five years, until July 1, 2023.

Safe harbour agreements hold significant potential as a tool to encourage and enable species at risk stewardship, but the use of this tool is in its infancy in Ontario. As a member of the federal Species at Risk Advisory Committee, I can confirm that considerable uncertainty remains in how best to utilize conservation agreements and under what circumstances. We certainly support exploring opportunities to use safe harbour and other conservation agreements to benefit SAR, but we are concerned that too many conditions on the future use of safe harbour habitat will act as a barrier to participation and discourage use of agreements. Extending the exemption period will also give the MNRF an opportunity to formalize the use of safe harbour agreements and allow the process to mature into a system that benefits both species at risk and applicants.

Thank you for considering our concerns and recommendations.

Yours in Conservation,

Mark Ryckman
Manager of Policy

[Original Comment ID: 213282]