To the OMNR and the OMECP,…

To the OMNR and the OMECP,

My name is Thomas McCay. I am an RPF and the Forestry Manager for Haliburton Forest & Wildlife Reserve. Haliburton Forest is a private landowner in Ontario who pursues sustainable and multi-use forest management as a business. We directly and indirectly own and manage ~250,000 acres of Forest in Haliburton, Muskoka, and Timmins. I am happy to respond to the ER posting as a representative of Haliburton Forest, as a Professional Forester, and as a concerned citizen. I'll provide my feedback as direct responses to the discussion areas highlighted in the posting.

1. A species-specific approach focusing on individuals and habitat makes sense when there is a highly threatened group facing specific and highly localized threats. It does not makes sense when those species needs are part of a broader landscape dynamic, and where the a marginal benefit to a threatened species results in negative implications for other wildlife communities. I advocate for integrating endagered species protection with landscape level plans wherever feasible. This could involve Crown FMP's and direct CFSA-ESA integration (or a section 55 solution), it could also involve other landscape level plans such as a Conservation Authority/Municipalities management plan, or a MFTIP plan which covers some minimum number of acres. These other solutions could provide relief through a section 18 or section 55 approach.

2. Having observed one COSSARO meeting, I was surprised by the general lack of committment or engagement by its members and supervisors. I have seen more active discussion at a university seminar. This raised concerns for me that the listing process was not being taken as seriously as it should be. Perhaps more compensation or other rewards are due to the members to encourage more careful review. Diversifying the membership of the committee to include individuals called in specifically for a species which is there specialty might also be appropriate. I think a lack of data can affect the committees decisions: Blandings turtle is a great example where the population estimate has exploded after it's listing, due to a higher search and reporting effort. Blandings turtle also highlights a geographic difficulty, where the species is really threatened in southern ontario, not in central ontario, but the listing wrongly restricts activity across its entire range.

Finally, I believe that the listing process should be impartial and apolitical, but the decision on how to respond to species threats should consider the all aspects of sustainability: social, economic, and environmental. Ministerial review of how to apply the listing decision or habitat description is appropriate.

3. I support the development of habitat protections which will help a species recover. But too often the precautionary approach means that a under-developed habitat description is rolled out which a) fails to truly help the species and b) is unnecessarily restrictive. American ginseng is a good example of an at-risk plant with a poor habitat description. In indepedent research, I have found that ginseng can tolerate mild disturbance and the disturbance can even help it expand it's range. But the habitat description follows a complete avoidance approach. On top of this, it is well known that the real threat to ginseng is poaching. In Mazinaw-Lanark, I have heard that technicians do not actually implement the buffers required under the habitat description, because it simply signals to poachers where there is ginseng to be found. They implement no buffers and the ginseng has not been experiencing any negative results. A better habitat description - and better policing - is needed for this species. There are many examples of this failure to properly identify the real threats, and how current listing, recovery plans and habitat description do little to help while imposing other costs: Blandings Turtle - Road mortality, Ginseng - poaching, Whip-poor-will - predation, fast traffic, loss of open area habitat. There are many other examples.

A more complicated examples involves woodland caribou. I had the privilege of watching a presentation from a senior MNR biologist on how the MNR arrived at the 35/65 disturbance threshold. I was left confused and unconvinced that this properly applied to Ontario's herds. And yet this approach may still form the cornerstone of the species recovery strategy. More time and better data are clearly needed.

4. My primary concern is Forestry. Because Forestry a) operates with a view to the entire landscape and all species, and b) provides site-by-site concern for individual species in management plans (CFSA FMP's, MFTIP, 3rd party certified plans) and guidance documents (such as the stand and site guide), and c) does not convert habitat away from Forest, and in general renews habitat rather than degrading or destroying it, I believe crown Forestry should have a permanent section 55 solution, and that other plans should be eligible for a Section 55 or Section 18 solution. This could be adapted where individual species have extremely specific requirements that Forestry does degrade or destroy.

In Summary, the ESA program needs:

A more rigorous listing process with enhanced membership, with the ministerial oversight of protections for listed species.

Habitat descriptions and recovery plans which target the true threats to a species, with better data and science to inform how to save a species.

Increased enforcement or policing of a species true threats.

A landscape level approach wherever an inidvidual species can tolerate it, and utilizing Section 55 regulations where possible for forest management. Section 18 solutions may be feasible for 'niche' forest managers.

Thomas McCay, RPF
Forestry Manager, Haliburton Forest & Wildlife Reserve
705-455-2503 / tmccay@haliburtonforest.com