In regards to ERO 013-4143,…

In regards to ERO 013-4143,

In their current form, COSSARO and the ESA are too easily abused by special interest anti-sustainable harvest groups. The ESA has proven itself clearly ineffective as seen blatantly in the handling of the "Algonquin wolf" and the protections of various reptiles and amphibians in Ontario. These are only two of numerous examples, of which any experienced wildlife manager could characterize as all being interconnected and affected by one another.

The relatively easy listing of the coyote-wolf hybrid, falsely recognized as the "Algonquin wolf" has triggered the complete abandonment of sound science and proven wildlife management methods, and threatened our ungulate and other mammal populations as well as the security of Canada's only true wolf, the Grey wolf. The protection of this hybrid violates the spirit of the ESA and does more harm than good by exacerbating the problem of hybridization and is resulting in unmitigated depredation of already struggling prey species. The recovery plan pertaining to the "Algonquin wolf" itself states that one of the greatest threats to the "Algonquin wolf" is further hybridization, but does nothing to inhibit the development of this supposed threat. Should this program be intended to be in the best interest of protecting species under its listing it is clearly falling short of making recovery possible. The ESA has quite obviously been used as an avenue to attack sustainable harvest which is clearly seen in the publicized recovery plans which create impossible problems to solve, ie. protecting hybrids threatened by further hybridization.

In addition, considering the current state of Ontario's reptile and amphibian populations, the ESA has glaringly failed a second time. Wetlands are lost everyday to ever expanding urban growth and agriculture with little to no effort taken to restore or rehabilitate tracts of lost wetland. The number one cause of wildlife decline is habitat loss and the ESA is powerless to address this problem. In addition, it also fails in its supposed purpose as a tool to develop species recovery plans. Owning the longest history of wildlife management within this great country, trappers have been the backbone of the great stewardship role in which Canada has in the past demonstrated its commitment too. Instead, the ESA has allowed novice conservationist whose opinions are based on emotion rather than science dictate recovery plan methods. These anti-sustainable harvest special interest groups have demonstrated their inability to grasp and implement simple conservation concepts and methods and have instead prioritized species to further their own agendas rather than recognize each species and value its role within the food web and ecosystem. One of the greatest threats to Ontario turtle populations aside from the aforementioned habitat loss, is unmitigated depredation by raccoons. Rather than promoting the sustainable harvest of raccoons, methods such as screening, sweeping, and costly veterinary treatment are being implemented. Screening and sweeping, if successful, only serves to divert raccoon predatory patterns to other prey species such as birds (many of whom are also listed under the ESA), resulting in another example in which the ESA is doing more harm than good. If proper and proven wildlife management techniques were implemented by those individuals with unique skills and experience, ie. Ontario trappers, species recovery would become a more realistic goal and foster sustainable predator populations rather than result in an over abundance in predator species and their inevitable collapse as a result in prey species decline.

I hope the government considers carefully the abuse of these current systems and more carefully ascertains in whom the more reliable and experienced wildlife management professionals are in this province and consult with those individuals accordingly. Sound wildlife management doctrine can prevent the majority of species listings, and the frequent reliance on the ESA only serves to further prove how ineffective it is a tool to recover species at risk. Protections should serve as a last resort, sound management should be the solution.