The Government Response Strategy identifies as forest management as a threat to the massassauga - in particular roads and clearcutting. While roads may seems like an obvious threat, I wonder if there has been any evidence that given the type of roads (ie. often winter roads), the low level of use, and the low level of speed, of forestry roads in the eastern Georgian Bay area really should be listed as a threat. Compared to municipal and provincial roads, the threat of forestry roads is, I would suggest with some experience, insignificant. Your GRS also identifies clearcutting as a threat. Although little clearcutting occurs within the eastern Georgian Bay range there is a small amount. However, your GRS provides no rationale, evidence or reference to any supporting documentation that would provide justification of including forest management activities as such a threat. It may also be argued that such forest management might actually be beneficial through habitat improvements for the massassauga and its prey. At the very least, threats should not be listed unless there is rationale to support the listing of the threat. It is hoped that staff working on this portfolio will take the time to discuss forest management concerns with local forest managers to come to a mutual understanding of forestry techniques employed in the area and what the concerns are about forest management.
Submitted September 12, 2018 6:16 PM