I have worked in forestry…

I have worked in forestry and conservation for more than 20 years. I currently teach forestry and worked alongside planners and taught urban and regional planning. I am also an avid hunter, fisherman, and trail user. While I am a strong believer in resource harvesting and well-planned growth, I am also a very strong believer in the protection and conservation of species at risk and their habitats.

As an overall statement, we do not know enough and may never know enough to be able to replicate species at risk habitat as a compensation measure. I have worked with grassland habitat creation efforts and am currently restoring forest habitat for an endangered species. Its success rate is low and only increases with increasing cost. It is cheaper to prevent and mitigate than re-create. There is also more than enough infill space in urban areas to build what is needed. There is no reason that we shouldn’t be able to avoid species at risk habitat while building what is needed. Infill, brownfields and additional houses on lots (that are included in the primary residence taxation), should be enough. If we are looking at species at risk habitat, then we are looking at sprawl and further destruction needed for infrastructure. We need to keep these lands as natural areas for nature as well as recreation, renewable resource harvesting and agriculture. Not houses. Furthermore, not unaffordable large houses that also require people to own vehicles and have high tax rates due to infrastructure that gets less use. We should be densifying urban areas. As well, if it is about getting people into homes, especially first homes, we should be removing the sales tax on used homes and only having it on new homes. Old homes have already been taxed and they are more likely to be the entry point in the housing market rather than an expensive subdivision house.

As far as more direct points of the proposal:

Government should not have discretion to remove from the species at risk list without due process and expert discourse.

There is much more to habitat than the dwelling or the root zone. While some definitions of habitat could be refined and better information could be gained through research, to so narrowly define habitat as is done in the proposal is not appropriate. The entire habitat of the species must be appropriately protected. If there is uncertainty in definitions, then fix that and don’t do away with the whole.

If they are in duplication with federal regulation (which some are), then it would be best to work with the federal government and have them allow the province to regulate them as the province has the best regional habitat specifics and knowledge.

I am glad to see the additional investment in species at risk conservation programs as these activities have so much more benefit than only species at risk.

Species conservation charges should only be used when there are no other options or when it meets a true urban infill goal. In fact, they should not be called species conservation charges they should be called sacrifice for profit charges. Someone should not be able to build a house in a natural, rural area and simply pay a species conservation charge. Furthermore, from what I have seen these charges are never enough as they are only usually the cost of the habitat (and we don’t even have the resources like trees and plants needed to adequately do that), they don’t include the purchase of land for that purpose. Therefore a lot of these types of schemes require that a conservation organization already owns the land which then continues to be a long-term degradation and loss from the whole. If this was going to be the case then true costing of land purchase that is not already suitable habitat for anything, for an area that is appropriate for the species and the needed density, with appropriate restoration costs should be charged. In many cases, this would be upwards of $25k per hectare and would often require at least 20-30ha if not more. They should be the REAL costs. Furthermore, a bond should be purchased that can only be canceled once the new habitat is created successfully and has demonstrated occupancy by the appropriate number of the species at risk for a specified period of time that would allow for true settlement and growth. This would be one of the few ways to adequately promote appropriate compensation.

The government should still be in charge of creating “recovery products”, otherwise who would provide direction for species conservation charges? Builder associations?

Harass should not be removed from the prohibitions. Otherwise, a proponent could harass a species to leave and then not have to pay the conservation charges (even though as I have stated the conservation charges concept is ridiculous).

I sincerely ask that these changes be reconsidered. Put in place some mechanisms to first promote infill and brownfield development before destroying the last vestiges of natural habitat. Most species at risk are such because their habitat is rare. There should be more than enough time during that phase to properly come up with a species at risk plan that will not sacrifice these species for the profit of builders. We don’t even know what the effect of the reduced number of international students will have on the housing market. In fact, put in greater taxation for houses used for airbnb and this would drastically increase rental and housing availability.