Comment
As a certified arborist and BHA, I do not agree with canning the BHA certification course. It is a valuable resource and one would not be qualified to assess butternut canker without it. The course should run online at the very least, however on site field exposure and discussing with experts is the best course of action. As an certified arborist (“qualified person”), I would not be able to assess butternuts without the course.
On the note of butternuts, I disagree with allowing the removal of any category 3 trees. They are few and far in between. There should be no allowance for the removal of a source of seed that may provide resistance and help repopulate the species.
When it comes to funding habitat creation how can loss of wetland habitat (blanding’s turtle) equate to grassland creation (bobolink/eastern meadowlark)? I don’t understand how pooling funds can create a better overall benefit when the 6 focus species have vastly different habitat requirements. How will this fund deliver a 1:1 ratio for all species habitat requirements with this method of doling funds?
One final note, I do not understand how the ESA funds will be doled out. If the agency cannot purchase land then how can they effectively ensure habitat creation to combat habitat loss? Would this be done through the SAR stewardship fund? I think there needs to be a more streamlined process so the agency is not sitting on funds meanwhile SAR habitat is dwindling.
Submitted December 18, 2020 6:52 PM
Comment on
A proposal under the Endangered Species Act to enable use of the Species at Risk Conservation Fund and to streamline authorizations for certain activities that impact species at risk, while maintaining protections for species at risk
ERO number
019-2636
Comment ID
50417
Commenting on behalf of
Comment status