My comments on the SAR…

My comments on the SAR review concur with those of the Ottawa field-Naturalists Club, which you have, and of Ontario Nature -

Any amendments to the ESA must support its purpose of protecting and recovering at-risk species. To that end, I urge MECP to:

- Repeal the 2013 exemptions for the forestry, hydro, mining and development industries;
- Amend section 57 (1)1 of the ESA so that exemptions will only be allowed if they do not jeopardize the survival and recovery of endangered and threatened species;
- Maintain COSSARO’s current science-based listing process;
- Maintain mandatory habitat protection with no ministerial discretion; and
- Maintain the requirement for proponents of harmful activities to provide an on-the-ground overall benefit to species impacted with no backdoor option to simply pay into a fund to compensate for harm.

Personally, my interactions with SAR in Ontario, as an independent natural historian and museum biologist, have been, besides discovering previously unknown SAR populations, mostly from citizen groups' requests for reviews of proposed habitat destruction in their areas. The revisions to SAR practice which these experiences suggest include:

1) Independent surveys for SAR. There are real epistemological problems in allowing a firm hired by the proponent of a habitat-destruction project to do the search for SAR, which, by definition are rare and easy to miss. This gives the searchers every incentive to do a slipshod job (such as listening for spring-calling frogs only when the temperature is below freezing). In every case the methodology of the EA's I have reviewed have been inadequate to find the SAR that were being "looked for," and in one case all the SAR were found by us from the periphery of a tract we were not allowed to enter, while the consultants didn't find any of them in the tract itself.

2) Disallow EAs that do not consult the peer-reviewed literature, local natural history groups and their journals, provincial and other online atlassing projects, and museum collections, to find current and historic records of SAR. There is often a complete disjunction between these traditional repositories of natural history knowledge and the "grey literature" referenced by consultant-authored EAs. In one case I published a first record of a species in eastern Ontario in the sole local natural history journal, only to find that the article wasn't found by the consultant preparing an EA for the destruction of the site where the species was found.

3) Instruct the Ministry of the Environment that it is their job to protect the environment, not to pander to the interests of proponents of habitat destruction. Every proposal and EA must be considered an hypothesis that can be accepted only after rigourous testing, and with the expectation that it will be falsified and the proposal rejected.

4) Require that projects which are undertaken to mitigate destruction of an SAR's habitat are adequately followed-up by monitoring paid for by the proponent, and that, if there isn't a net increase of the mitigated species after an appropriate lapse of years, the proponent, or their heirs & assigns, undertake further habitat creation - on the basis of accrued knowledge of the species' requirements - to remedy the failure of the first effort.

5) Ensure that newly created - anthropogenic - habitat patches which could support local SAR are colonized by the species (plural), either naturally or with human assistance. If the Eastern Pond-mussel is endangered by Zebra Mussels in its natural lake-shallows habitat, it should be introduced to every new pond in its historic range which supports its host fish species, so that it can persist in each region where it formerly occurred.

In general, the presence of SAR should be a trigger to protect and expand natural habitats. It's clear than humanity has an excessively large ecological footprint, so the goal of all planning should be to retract human intervention from the landscape, if only so that expanded wetlands and forests can sequester carbon to help stabilize the climate (the habitat of grassland SAR can be moved towards native prairie, where the large root biomass also sequesters carbon).

I hope this review can help Ontario take SAR seriously as an emblem of, and trigger for, sustainable human habitation of the province.

The Chorus Frog song may clarify thinking on some of these matters - https://soundcloud.com/aletakarstad/for-the-frogs/s-K1anI - "Creakers" and "Ratchet Frogs" are vernacular names for Chorus Frogs, and "Simplex sigillum falsi" ("simplicity is the seal of falsehood") is a principle of scientific philosophy elucidated in "The Myth of Simplicity: Problems of Scientific Philosophy," by Mario Bunge (1963).

Hey, Boomers and zoomers all over the land
stop doing the stuff that you don't understand.
Your sons and your daughters have sucked up your plan,
and Ontario's sadly degraded.

Creakers and Peepers in swamp and in field,
will show what your "land use policies" yield,
and if you can't hear them, then boy, you have failed
and the the whole place is drained and paved over!

...just take a listen to what you can't hear – for the frogs, things are a'changing.

"Simplex sigillum falsi" – please heed,
That is the motto that all planners need.
You must live it out truly in word and in deed
if you want to hear frogs in the evening.

Landscape ecology has the programme -
defrag the country to reconnect land,
and Ratchet Frogs flourish in little wetlands -
in Renfrew and Cloyne and Southampton.

...just take a listen to what you can't hear – for the frogs, things are a'changing.