The ESA is an effective act…

The ESA is an effective act I believe for site specific projects such as a bridge, a housing development, a golf course or other area that is limited in size but has significant long term and acute impacts. As a forester, the ESA is not an effective or particularly useful act for the health of our forests including Species At Risk. I say this because:
1) the Crown Forest Sustainability Act provides protection for forest dwelling SAR and in a manner that considers all species - SAR or not,
2) forestry activities are NOT the reason species at risk in southern Region (i.e. snakes, turtles, whip-poor-will) have made it onto COSSARO's list. However, since they are on the list, government policy is overly restrictive and discriminatory against forestry workers and by extension their families and communities;
3) The ESA suggests under Section 17 and 18 permits or using a FMP as an instrument under the act but what sounds reasonable on paper falls well short in real life. Multiple species, large areas, over several years and many treatments (harvesting, site preparation, tending, planting, access) being involved makes these mechanisms overwhelmingly complex, open to constant debate (e.g. overall benefit measures) and therefore uncertainty for forest managers and the logging community to plan and carry out the sustainable work they have been doing for decades.
4) When forestry occurs, there is no damage, destruction or harassment - there is only a risk - and most often a very very slight risk of damage, destruction or harassment. Any rules, restrictions and overall benefit type of approaches should be reflective of this very small risk. i.e. if someone is going to drain a marsh that is the home to Blanding's turtles to build a golf course, the rules and compensating overall benefit needs to reflect that certainty of harm and destruction. When someone is merely harvesting in an area and driving down a forestry road with slow speeds, very little traffic and driver training (and with virtually no evidence of history of harm occurring), rules and restrictions should be a tiny fraction of those for the golf course issue.

Also, species that get listed on COSSARO seem to do so because of people passionate about that species - often by people with no local knowledge of the forests that resulting rules and issues that are impacted. Then, people start surveying for them and it turns out that populations are much higher than thought yet some biologists continue to convince COSSARO that the species should still be a SAR. For example, I had a biologist in a field tour once say correct someone in the group that quipped there are hundreds of blanding's turtles. The biologist quickly said there are not hundreds, but only dozens. Then people start looking and recording and there are indeed obviously hundreds, if not thousands...yet the status continues to apply. Why? Where is the field based expertise..the local expertise. Someone studying turtles south of Toronto or Barrie have no experience what the turtle population is between Bancroft and Georgian Bay.

This brings up the point about why species are SAR. Over development for urbanization, farmland, golf courses and a myriad of roads in southern Ontario i.e. south of the Canadian Shield should not be used to list species on COSSARO except as only a regional species...so as not to include many restrictions on the landscape that covers much of our Shield without that level of development. E.g. there are literally thousands of aquatic features for Blandings turtle across the GLSL Forest in which the Area of the Undertaking for Forestry on Crown Lands occurs. Yet, it seems comparisons are being made to the level of development and lack of such features that still exist on the landscape in the 416, 905, 519 and the very southern 705 area codes. i.e. Peterborough, BArrie, Ottawa, Cornwall, Kitchern, Collingwood and Chatham situations are vastly different than those of Bancroft, Cloyne, Algonquin Park, and Parry Sound. Treating them as the same does a disservice to the economic well-being of Ontario, especially rural Ontario that relies on forestry and does very little to the very SAR the ESA is purporting to protect. Regionalization of COSSARO listings should be used in conjunction with local field people. There needs to be sufficient time for listings and how they may be applied as well.

Thanks you for the opportunity to comment.