The proposed definition of …

The proposed definition of “habitat” is an exercise in logical absurdity. For animals, the definition of habitat is basically a cage. The restriction of a plant’s habitat to the “critical root zone” is basically the definition of a plant pot.

Any definition of habitat, whether for a plant or animal, MUST include not just the local area occupied by a nest, but also the other organisms on which the target species depends for its survival. Thus, a pileated woodpecker, a keystone species, may require, at minimum, 20 – 25 large decaying trees per hectare of habitat to provide food source and nesting sites. For a plant, habitat MUST include maintaining the integrity of the local hydrological system and light regime on which the plant depends. Thus ,a plant that depends on seeps or wetlands, such as the eastern prairie fringed orchid, will not be able to survive if conditions are altered in a way that leads to drying out of the habitat (e.g., by drainage, peat harvesting, or paving).

As an ecologist with 30 years of experience on three continents, I find it exhausting to have to repeatedly explain basic ecological facts to government functionaries. Any child could look at your attempted redefinition of habitat (as cages and plant pots) and see instantly the true intent of this process, which is to get endangered species out of the way of development.

The ecological illiteracy implicit in the language of habitat is compounded by the unreasonable discretion granted to the government to add or delete species from the threatened and endangered list. This language undermines the role of actual scientists from the Committee on the Status of Species at Risk in Ontario (COSSARO), who make decisions on endangerment through an appropriate, science-based process. POLITICANS ARE NOT COMPETENT TO MAKE THESE DECISIONS.

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