Focus 1 In many cases, a…

Focus 1

In many cases, a more habitat/landscape based approach would bring many benefits. This is most obvious when ones species-at-risk preys on another or when they compete for the same resources. In many cases, the needs to different species at total odds and cannot be resolved in the same physical location.

More land should be conserved for the purpose of simply making it habitat, rather than _______ habitat. If were were able to look back 100 years from now, I think we would be want ourselves to protecting more land rather than simply protecting more species, many of whom have contradictory habitat needs and/or were only common in Ontario in the first place because all the forests were cut down 200 years ago.

Focus 2

I'm not sure if the claim that there is not enough public notice prior to listings is true. The examples I can think of had plenty of time for misinformation to spread far and wide before any decisions were made. Certainly this is the case with the prominent ones. Maybe that's just my impression from being in the conservation community, but I suspect that within the agricultural or development sector, they catch wind of likely listings well in advance of any decisions being made.

The main issue I see with automatic protection of habitat is that often the habitat definitions are nebulous. This leaves too much gray area and with too much potential legislative weight behind it for anyone's good. When the habitat definitions are well defined for the species both in geographic scope and in description, then it's a good thing. There are also some species whose critical habitat cannot be defined so clearly, either before they are too broad geographically or too poorly understood. In these cases, and with proper justification, there should be the option to delay habitat projection until it can be properly researched and defined. In all cases, the habitat definition ought to be something that landowners, businesses, and residents can reasonably accommodate.

Many of the species listed actually rely on human activity, and their recent decline follows a population high that was a direct result of previous human activity (the clearing of much of our forest for agriculture, barns on small abandoned farms, etc). The listing process needs to do a better job of defining the causes of the decline (in other words, the reason the populations were higher in the past). A specific example of that is the Bobolink, which would have found Ontario's habitats extremely unfavourable until about 200 years ago when most of our forests were cleared for small-scale farming and pasturing, but who are now hurt by a shift toward larger scale cash cropping. A number of the most prominent listed species fall under this category.

Focus 3

In theory, strict time-lines for protecting of species and reporting on them is good, and in practice it often is. But there can be some big downsides. The time-line for a recovery strategy is one of these. What if there isn't sufficient information available to determine how best to recover a species? What if not enough is known about a species' habitat but yet a timeline has determined that habitat protection must come into effect? Both of these situations do occur, and often an incomplete or inaccurate habitat definition is rushed out and put into law simply to meet a deadline.

The GRS does, at least in principle, outline the government's obligations towards a species' conservation. And because the government, again, at least in principle, represents not just those most interested in conservation but also everyone else in the province—whether or not they voted for the government in power—it's not a document to rush. Nine months is probably too quick a turnaround, but there should still be a firm time-line, lest a government be tempted to use delay as a strategy for inaction.

Both the GRS and Recovery Strategies themselves should be revisited periodically and, if warranted, revised. A lot can happen in 15 or 20 years and if the guiding documents haven't been updated accordingly, that can lead to guidelines and legal requirements that are out of step with current needs.

In some cases a general habitat definition would apply in lieu of a specific one. But typically different species have different habitat needs, sometimes markedly so. This does highlight one of the downsides of shaping all protection to individual species needs, rather than a broader landscape approach. That said, I suspect that all of the species who would benefit from strong individual habitat projection have already been listed.

Focus 4

There is one glaringly obvious solution to the issues presented in Focus 4: Ensure that district MNRF offices have the staff to do the job.

The district offices have been slowly eroded over the years, but most notably within the last decade the Liberal Government severely curtailed the operational capacity and staff of most district offices. This often prevented the remaining staff from doing their job in a timely manner and resulted in businesses having to wait much longer for permitting than they should have. Simply allowing those districts the funds and staff to see through the authorizations would resolve the backlog.

The exact same root cause is at play with the inability to inspect and enforce: The districts tasked with this job simply no longer have the manpower.

Mitigating actions (Overall Benefit) should also take into consideration the resources of the company applying for the permit. Small local businesses do not have the resources available as large multi-billion dollar multi-nationals and should not be expected to mitigate at the same level. Some overall benefit strategies might also be better if they focused less on the individual species and more on habitat.

Closing comment

Lastly, one overarching piece of advice for the current government: Remember that governments change and it can be quite simple to reverse the decisions of a previous government. If you want your changes to stick beyond the next election (let alone win the next election), you need to make sure that you are adequately involving the other 62% of the electorate in the decision making process. Don't make the mistake the previous government made and assume that 38% of the vote gives you a mandate over the province. That mentality will only set you up to lose big in a backlash vote and have all your signature legislation reversed.