The County of Renfrew…

ERO number

013-4143

Comment ID

22928

Commenting on behalf of

County of Renfrew

Comment status

Comment approved More about comment statuses

Comment

The County of Renfrew welcomes a review of the Endangered Species Act (ESA) in its 10th year.

The attached documents outlines issues we have observed and experienced, and heard from forest sector stakeholders in our area. Solutions are presented for each issue and are fully described in the document. In summary, these solutions are:

1. Evaluate species populations and determine COSSARO status geographically.
2. More research should take place on actual risk posed by forest management in species at risk (SAR) habitat, particularly Blanding’s turtle, ginseng, wood turtle, and whip-poor-will.
3. Recognize that a coarse-filter, landscape level management approach attempts to provide habitat for all species and aims to emulate natural disturbance patterns. When appropriate, site-level requirements in species at risk habitat must be science-based, evaluate risk, consider other species and values, and be subject to change when new science emerges.
4. Recognize that, in a landscape where fires are suppressed, forest management is the key to maintaining healthy, natural ecosystems. Many species at risk benefit as a result of the disturbances created during forestry activities – whip-poor-will and the Algonquin Wolf are excellent examples. Species protection measures should align with this, not restrict the ability to create or maintain SAR habitat.
5. Evaluate if COSSARO is the most transparent, meaningful and effective way of designating species at risk in Ontario by comparing to methods used for evaluating in other provinces.
If COSSARO is to continue in its current function, include more diverse representation of broader skill sets on COSSARO. COSSARO should include stakeholders such as forest practitioners (Registered Professional Foresters), Indigenous peoples, and others with knowledge and experience on the landbase.
6. Allow adequate time and resources to properly evaluate recovery strategies, complete realistic socio-economic impact analyses, and consider input from stakeholders and Indigenous peoples. These analyses and their impacts should be shared with stakeholders before policies are implemented.
7. As new population data and science emerges, regular COSSARO reviews should occur to determine if a species’ designation should change. The timeline for this should not be extended, and in some cases, may warrant acceleration.
8. Enable the CFSA to act as the legislation that manages for and protects SAR on Crown land in Ontario.
9. Sustainable forest management should be recognized as good land stewardship. Providing clear, reasonable guidance on how to manage forests in species at risk habitat could improve the public’s attitude toward species at risk in rural areas. Develop an effective, positive incentive program for maintaining habitat or potential habitat.

Supporting documents