10th year Endangered Species…

10th year Endangered Species Act review discussion paper

The comments below are listed under each of the 4 areas of focus in the discussion paper.

1) Landscape Approaches

Where recovery approaches for individual species conflict with one another, a landscape-level approach can be effective in some cases as a compliment, but certainly not as a replacement.

The act already includes the tools needed to apply a landscape approach. No changes to the legislation are needed to implement this.

Existing landscape connectivity modeling tools based on circuit theory (e.g. circuitscape) have been successfully used by ontario university researchers and by research scientists in the ministry of natural resources to model the movements or gene flow of specific species or species guilds.

2) Listing Processes

The discussion paper cites the challenge of not enough public notice before listing, and that automatic listing may result in delays or cost to development projects.

Evidence from the federal Species at Risk Act and former ESA legislation suggests that “political listing” often results in delayed protections or no protections at all. Longer timelines for listings and delayed protections serves only the developers who stand to experience complications from listing, it in no way serves the species that are in dire need of protection and recover.

Many improvements could be made with regard to COSARROs process of assessment and classification. COSARRO members are not paid for their work. With compensation they would be able to do much more in terms of communications/notifications with stakeholders. To increase transparency, they would also be able to invest in monitoring of recovery effort effectiveness (to improve the scientific basis of assessments).

3) Recovery Processes & Habitat

There is no benefit to changing the legislated timelines of the GRS and progress reviews. Evidence suggests that the most effective way to help species recover is by protecting habitat, and therefore that habitat regulations are extremely valuable and necessary.

More attention should be devoted to coordinating the process of GRS and recovery strategies by creating recovery strategies and GRS for multiple species sharing particular geographies or facing similar threats (i.e. landscape approach).

4) Authorization Processes

A habitat banking system (I.e. paying into a conservation fund) in lieu of activity-based requirements is not sufficient as there is no assurance that direct compensation for impacts will be completed. Instead, the focus should be on habitat protection measures that are effective for listed species and benefit multiple species, and addressing the needs of species as early as possible in development activities (i.e. at the planning stage). The more protection is deferred, the more complicated and expensive it becomes to address recovery needs.