To whom it may concern, I…

To whom it may concern,

I think a more landscape approach is beneficial. A lot of the housing developers (especially in Ottawa where I am from) have been able to get through loops in the system because of the current case-by-case and species-specific approach. A single site can have multiple species at risk or endangered present and non-endangered species rely on these species for the overall health of an area. "Specific geographic areas or ecosystems where the needs of multiple species at risk can be addressed", I think is the best possible way to achieve a more broad and strategic approach.

The KNL development of the South March Highlands in Ottawa was a prime example of what this proposed change to the Act could have influenced on the outcome. I saw first-hand the clear cutting of native at-risk trees and the removal of Blanding’s Turtle habitats from land grading by housing developers in my city because they are getting through loops in the current system. Currently if only 2 or 3 species at risk are mentioned in an application and the developer has "reasonable" alternatives for mitigating the habitat loss and there is an “overall benefit” then the project gets the green light. KNL’s proposed measures consisted of no more than mitigation, for example, the extensive fencing that would be erected to channel Blanding’s Turtles into corridors and construction of new nesting and overwintering sites that they hope the turtles will make use of. These are experiments; that they would be an “overall benefit” is speculative.

Even if 1 of the 3 species were not found or present on the site for the few days the biologist (hired by the developer might I add) was there, the project still gets a green light. The Act allows some activities to proceed under a clause 17(2)(c) permit with specific conditions if: avoidance and reasonable alternatives have been considered. This is a fundamental misinterpretation of the legislation. When the Endangered Species Act refers to “reasonable” alternatives, it means reasonable with respect to achieving the objectives of the Act, as in, the protection of the endangered species. The profit of a developer does not come into it.
Pin-pointing a few species at risk in an area and formulating a few management strategies for each individual species in an application is a one-dimensional approach than if an entire geographic area were in question. The way species interact with one another is far grander than containing and reducing an area down to 2 or 3 species.

THE PROVNCE NEEDS MORE POWER. Habitat protection is under the Act. But a species-specific approach has allowed the developer to continue habitat and species destruction because the land, the boundary, in which endangered species lives on is not officially protected. Even though endangered and at-risk species are present the developers are able to come up with a few strategies for mitigation and are light on the fact that “some” of these species will be killed in the process. A landscape approach would fill the gap in the missing legislation.

Habitat boundaries of endangered and at-risk species should be heavily analyzed if the province wants to transition to a landscape approach to implementing the Endangered Species Act. Species on the at-risk or endangered list found in an area should not be up for debate in a proposed development site. A landscape approach would mean more land would be out of the question for development. I am not so sure this would yield the economic activity the province is hoping for but it certainly is a step in the right direction for saving and securing the habitats of endangered species.