Thank you for posting this…

Thank you for posting this notice. I very much appreciate the opportunity to provide comments based on my 12 years of experience working with Species at Risk (SAR) in Essex County (this submission will also be sent via email with all supporting documents). The proposed development is within the Ojibway Prairie Complex and Greater Park Ecosystem (OPCGPE), an Important Amphibian and Reptile Area , and a landscape that Wildlife Preservation Canada has been directly invested in since 2013 .

1) I agree that the proposed development of 3 residential lots on Sovereign Dr. in LaSalle would result in adverse effects to 3 SAR snake species and their habitats (Butler's Gartersnake, Eastern Foxsnake [Carolinian pop.], and Massasauga [Carolinian pop.]). Unfortunately, no proposed development plan was presented showing lot boundaries, nor was the size of the development footprint reported. As a result, it was difficult to fully understand how the proposal may permanently impact SAR, their habitat and movement corridors. Also, the proposal states that 1.0 ha of existing adjacent habitat will be protected, which I am strongly supportive of – habitat loss has historically been one of the greatest threats to local SAR reptiles. Unfortunately, no details were provided on precisely where habitat protection will occur, the current suitability of the 1.0 ha site for SAR snakes, nor how the land will spatially contribute to landscape connectivity. Therefore, it was impossible to determine the significance of the amount of habitat to be protected in comparison to how much habitat would be removed (and subsequently, whether an overall benefit would be achieved). My comments must therefore be based on informed speculation using general site location details presented in the ERO posting in combination with publicly available aerial imagery and parcel fabric. I strongly recommend that future ERO postings provide greater detail to facilitate the submission of informed comments (see ERO #019-2504 for an example).

2) The proposal does not list impacts to Blanding’s Turtle, a Threatened species in Ontario. A map of potential regulated habitat for this species was produced using confirmed occurrence data and applying the general habitat description by MNRF. The results suggest that the proposed development site may be impacting Category 2 and/or Category 3 Blanding’s Turtle habitat (see Attachment 1). Therefore, the impact to this species should be accounted for in the permit application.

3) WPC has been working with local partners to create a 5 km long functional wildlife corridor for SAR reptiles stretching from LaSalle Woods to Ojibway Park, and following an existing utility right-of-way (see Attachment 2). The corridor design has been informed by research on road ecology and landscape connectivity that began in 2010 (Choquette and Valliant 2016 , Choquette et al. 2020 ). Also, WPC has secured permission to conduct targeted management activities along this corridor through the Provincial Secondary Land Use Program annually since 2017. We request that the proposed development not compromise the intent and functionality of the wildlife corridor and that overall benefit activities are implemented in such a way as to protect and enhance its ecological function.

4) The proposed development site would impact a Town of LaSalle Candidate Natural Heritage Site (CNHS TC1; ~9-13 ha in size; see Attachment 3), previously identified based on its significant natural heritage features . This CNHS includes portions of Tallgrass Prairie, a globally rare ecosystem, and supports at least 3 SAR plant species. The Town of LaSalle Official Plan states that “The Environmental Impact Assessment/Management Plan shall demonstrate that the proposed use will have no negative impact on significant natural heritage features and areas and their associated ecological functions.” (p.69). Also, the Massasauga Government Response Statement lists the objective to “Protect and improve the quality of existing habitat and increase habitat connectivity (Carolinian population)”. CNHS TC1 has been identified as a necessary habitat patch to facilitate functional connectivity for Massasaugas between two SARA-listed Critical Habitat blocks (p.21, Choquette et al. 2020; see Attachment 4). Furthermore, this habitat patch must be preserved above a minimum size threshold to maintain this ecological function (i.e., 5 ha; p.7, Choquette et al. 2020). The proposed development, in combination with other proposed residential developments nearby, would result in a substantial overall size reduction of CNHS TC1. For example, current zoning suggests that full build-out would leave only ~4.2 ha remaining in a contiguous block along the utility right-of-way (estimated from Town of LaSalle Zoning By-law, Schedule C, Map 02 ). Should CNHS TC1 be reduced to that extent, a major ecological linkage for Massasaugas would become permanently degraded, severely compromising recovery of the Ojibway Prairie population. This proposal must consider the cumulative impact to CNHS TC1, and confirm that a large enough contiguous block of SAR habitat would be preserved.

5) We are very supportive of the proposal to install wildlife guiding features (e.g., barrier fences) “along/in the vicinity of Todd Lane to encourage wildlife, including snakes, to cross through the Turkey Creek floodway/riparian area, rather than across Todd Lane”. In principal, this proposal would contribute toward increasing the functionality of the wildlife corridor mentioned above (point 2). There is an existing chain link fence system at Todd Lane that could be upgraded with snake barrier mesh to partially achieve the above-stated goal. We do not recommend the use of “armourstone” as a barrier system, however, and caution that to prevent snake access to the roadway barrier fencing will be necessary (snakes are great climbers!). In addition to providing copies of our relevant published work (e.g., Choquette and Valliant 2016; Choquette et al. 2020), WPC would be happy to provide additional advice and information on road mortality hotspots and ideal locations for barrier fencing in the area.

6) Regarding actions to minimize adverse effects, I am fully supportive of “installing a permanent fence along northern, eastern and western boundaries of the properties to reduce encroachment into adjacent habitat” but stress that the permanent fence must have a snake barrier mesh installed to prevent SAR access to the residential development. A fine mesh (e.g., 1/8”) has become the standard used in the OPCGPE to prevent snake access to roads and residential areas, however, it is fragile and requires regular maintenance to ensure long-term integrity. The permanent fence should also be installed in such a way that it is continuous with existing fencing in the area (e.g., north of Serenity Circle, NE of Sovereign Dr. and Richmond Crt.) to create a seamless barrier that would keep SAR snakes within protected habitat (out of the residential area), and encourage movement along the wildlife corridor.

7) Related to point 6), the construction of temporary “snake exclusion fencing” (e.g., silt fencing) is a waste of resources when these fences are poorly installed and/or not maintained on a very frequent basis (e.g., weekly). A sound investment would be the installation of the permanent barrier fence (e.g., chain link with snake barrier mesh) around the perimeter of the construction site up-front to prevent snake entry during construction and for many years afterward. An added benefit of this approach would be a reduced or eliminated need for three of the proposed actions to minimize adverse effects: 1) “maintaining the development area free of any debris.”, 2) “providing awareness training regarding … to on-site personnel engaged in construction activities”, and 3)“capturing and relocating Eastern Foxsnake, Butler's Gartersnake and Massasauga if found on-site”.

The ability of the OPCGPE to continue to support important populations of SAR reptiles, and the recovery of the Ojibway Prairie population of Massasaugas, will depend upon the protection, restoration and enhancement of landscape connectivity between large protected natural areas. As currently presented, the proposed development has the potential to permanently impede landscape connectivity for SAR reptiles and should not be approved unless the above-mentioned concerns are properly addressed.

Thank You,

Jonathan D. Choquette, BSc, MLA
Lead Biologist - Ojibway Prairie Reptile Recovery,
Wildlife Preservation Canada