These comments pertain to…

These comments pertain to ERO proposal 013-4143.

I am concerned that a landscape approach for managing species at risk within specific geographic areas or ecosystems may allow the erosion of habitat quality for some SAR species that operate at smaller geographic scales. A landscape approach might be used to rationalize development that negatively impacts species habitat at smaller spatial scales by suggesting there is a large supply of a specific habitat type at the landscape scale, when in fact, site specific habitat could be critical to a species population. For example, one hibernacula (habitat complex supporting many hibernation sites) might be critical to a meta population of massasaugas within a landscape that has many potential hibernacula complexes. If that particular hibernacula is not protected, there is a high level of risk that that meta population will be severely reduced or extirpated. Some species have very strong fidelity to specific habitats and limited ability to find, or adopt new habitat serving the same function.

It is not clear what is meant by a more strategic approach supporting a proposed activity while also ensuring or improving outcomes for species at risk? I believe that a strategic landscape approach must not assume that a sufficient supply of habitats at the landscape scale can be relied upon to serve multiple species well when the spatial ecology of each of the species involved is not well understood at the appropriate spatial scales. Strong habitat protection policies and legislative requirements applicable to all spatial scales will be necessary. There is also high risk that fragmented landscapes will result over time, thus creating barriers to movement and limiting species survival and dispersal.

One existing tool or process that supports managing for species at risk at a landscape scale that could be recognized under the Endangered Species Act is comprehensive natural heritage habitat mapping and protection. Existing habitat regulations under the Act do this for single species. To map habitat comprehensively at a landscape scale is prohibitively costly and time consuming, and would primarily be a cost for the government to bare. Now, proponents of developments bare this responsibility for private lands, or when permits are required by utilities for activities on crown land, although many of these have now been exempted. If the government is looking to be cost efficient and effective at conserving SAR species, habitat must be protected now. The risk to species persistence, the cost of habitat rehabilitation and the cost of other types of intervention (repatriation, translocation, rescue, captive breeding, reintroduction, etc.) is much greater later on. The efficacy of recovery actions cannot be compared to good conservation practices in the first place.

I agree that in some cases the time to develop the Government Response Statement for an endangered or threatened species is too short. However, if a decision is made to allow an extension of this time frame, it must be restricted to a reasonable period of extension, i.e. no more than 6 months, and it must be restricted to a one time only extension.

I disagree that conducting a review of progress towards the protection and recovery of a species within five years of the Government Response Statement is too soon. This time period holds the government to account, to ensure that actions are being taken before it is too late. Extending this response period might relieve the pressure on government allowing it to defer action.

I disagree that the development of a habitat regulation is not needed for each species that is endangered and threatened. General habitat descriptions are not sufficiently detailed to ensure protection applies to specific habitats that need protection. There would be too much room for dispute.

Enabling paying into a conservation fund dedicated to species at risk conservation should never be used as an option to authorize the destruction of habitat or the harm, harass or killing of an individual.

Using a conservation agreement in place of the appropriate permit required under the Act would only be acceptable if it ensured that sufficient information on potentially impacted species was known (collected) in advance of development plans being formulated, these plans being reviewed and endorsed by qualified government staff and approvals granted. The agreements would have to be enforceable under the SAR Act. In other words a permit by another name. There is no substitute for the requirement of species and habitat protection if the government intends to meet it's obligations to protect species at risk.

If the government hired a sufficient number of inter ministry expert ecological assessment teams containing staff which would work with small and medium sized developers to assess properties, map habitats and analyse plan options, conditions of agreements could be developed and approved with minimum cost to developers and minimum delay. However, the government would have to bare additional costs in staffing and support. This approach could also promote more efficient review and approval for activities subject to other legislative or regulatory frameworks.

Enhanced enforcement powers should be authorized for any high risk files or developers with history of offences. All large developments potentially impacting multiple SAR species and any files flagged by the governments team of ecological experts.