Bill 184 species at risk

[aniceguy]

Yesterday I was an invited stakeholder to present perspective on Bill 184 at Queens Park. Below is my briefings for the standing commitee and the EBR official response towards Bill 184

 

Its a long read but should give you some perspective. Lots more to come in the following weeks

 

Subject: C.R.A.A.. Response to EBR Registry # AB06E6001 - Ontario’s Proposed Endangered Species Legislation

Presentation to standing committee room 151 Queens Park

 

General Comments on Bill 184

 

Credit River Anglers association has expressed support of Bill 184 in principle, but in due course have grave concerns over the frame work of this legislation and how its obligations will be fulfilled under the perimeters of the current Culture within the various ministries that will be eventually responsible for this.

We believe that this legislation will result in increased costs and subsequent cutbacks to derive funding, and the net potential economic loss to stakeholders, governments will occur without any measurable and quantifiable net gain for species at risk

 

 

CRAA is fully supportive of the recovery of Ontario’s biodiversity and the protection of habitat but feel this is not the appropriate path to set forward with it.

 

We believe that the appropriate level of consultation on bill 184 has not occurred in order to capture stakeholder and the public’s opinion and considering its socio-ecologic complexity and its potential to create another regulatory hurdle for citizens to overcome

Without adequate funding to sustain bill 184 and without the transparency a bill such as this should encompass we believe the potentially exists to create yet another level of complexity without the appropriate guidelines to deliver this service

 

Currently as Ontario enters the streamlining of fishery management zones we believe that Bill 184 has not been introduced into enough management Zones to receive the appropriate consultation it requires as pertaining to fisheries based decisions.

 

All stakeholders have the ability to be represented within their respective FMZ zones. We also believe that each zone has unique opportunities to protect species identified at risk and that each zone should require an adequate stakeholder identification process, review and consultation period. At the very least Bill 184 should be deferred until these new zones gain approval and the respective stakeholders can review this legislation and provide input

 

This legislation was drafted, tabled and debated prior to EBR consultation closing a further point towards the lack of consultation of stakeholders. We question if Bill 184 could address these same stakeholders without the background consultation being done and fear that there is in adequate funding to support the stewardship program that is in place and has the potential currently from preventing a species from becoming endangered in the first place.

 

 

Our friends form OFAH also agrees in the fact that the Province must be aware of the Independent Advisory Panel recommendation 2.4 (Financing the Implementation of the Act). This is most relevant today. It reads:

 

“Adequate resources should be allocated to the start-up and ongoing implementation of the new Act because financing the Act will be critical to its ultimate effectiveness.”

 

 

We are of the strong opinion that the $ 4.5 million dollars per year will not even cover administrative, capital and sector development costs to the government. Its also our belief that these funds can be used to support existing programs We are also in agreement with our friends in Conservation at OFAH in the following statement

 

 

“ We do not believe that $4.5 million per year for the next four years will even begin to cover the costs to which will include but not be limited to increased enforcement needs; considerable staffing to fulfill requirements for species-by-species regulations; species-by-species management planning; recovery planning; staffing for complicated permitting procedures; agreement negotiation, and all of the bureaucracy that entails; staffing for field proofing; investigations of complaints; interpretation of habitat definition in the field for the purpose of protection; related policy development; communications and outreach; stewardship programming (none of which includes anything actually spent to implement action plans, nor compensate landowners for lost production, nor secure one acre of species at risk habitat, nor improve one stream for species recovery).”

 

 

Based on Background data we believe that the appropriate course of action is to allow Bill 184 to be sent to the newly created management zones once approved as a geographical template and to allow stakeholders to comment. We also believe that the proposed bill does not have adequate funding as evidenced by estimated capital expenditures of the US government.

 

“In 1989, the U.S. Fish and Wildlife Service reported Endangered Species Act expenditures of $43.7 million. Eleven years later, it reported annual E.S.A. expenditures of $610.3 million. Independent accountants claim “the actual government costs are probably four times that estimate” (see Property and Environmental Research Center Accounting for Species www.perc.org/pdf/esa_costs.pdf ).”

 

While the scale of population demographics may be modeled in a downward trend to reflect Ontario’s demographics in essence the $4.5 million falls far short of any tangible and measurable results. Ultimately citizens would be better served if these investments were re directed into severely under funded stewardship programs.

 

 

 

 

 

 

Species at Risk in Ontario

 

This section required additional input and rephrasing to give ministerial authority and governmental accountability to date we feel that the majority of science is not available to determine a species at risk list.

It must retain flexibility in order to give the Minister the authority to determine the listing of a species and must be based on sound science.

 

 

 

The newly created Ontario Biodiversity Strategy has two primary goals

 

The conservation of Ontario’s biological diversity and the sustainable use and development of biological resources. Bill 184 should require that any management or recovery planning for species that are sustain ably harvested should be developed in cooperation with those key stakeholders. Much of this background data can be captured within management zone stakeholder groups. We also believe that in many cases and in particular of cold water salmonids major data gaps exist as to the final determination of what sustainable harvests are.

 

Stewardship Programs.

 

Currently the fish and wildlife fund CWFIP is serviced by 28,000 on the ground volunteers who draw from an annual 1 million dollar budget. These same volunteers can have a higher rate of success in the protection and recovery of threatened species through voluntary agreements and the cost to Ontario citizens is ¼ less and would be far more economical then a burueaucratily legislated program.

 

CRAA feels that proposed permits procedures will lead to an onslaught of bureaucratic red tape and in fact has the potentiality to provide delays, court challenges and can potentially open avenues from additional proponents in how currently naturalized salmonids populations are managed, once again this has the potentiality to be in direct conflict with Ontario’s biodiversity and sustainability directive by forcing the hierarchy of how fish populations are currently managed.

 

A direct Quote from the Ontario Federation of Anglers and Hunters EBR posting

 

The Importance of Prevention

 

“Less than one year ago when the Province kicked off its discussion paper Toward Better Protection of Species at Risk in Ontario, and the extremely limited public consultation that followed, it introduced its intent with the following statement:

“Helping a species at risk recover can be costly and complex. The best course of action is to prevent any species from becoming at risk in the first place, through responsible land use stewardship practices. Proactively protecting species at risk, and precluding the need for recovery actions, goes hand in hand with the province’s commitment to a strong economy and healthy communities.”

 

 

 

It goes on to state that the province’s Place to Grow Act and the Greenbelt Act “are just two examples of legislation that will help to ensure protection of Ontario’s species at risk.”

 

What it did not attempt to explain is that species at risk protection is also served, to greater or lesser degrees, through the Provincial Parks and Conservation Reserves Act; the Fish & Wildlife Conservation Act; the Municipal Planning Act; the Conservation Authorities Act; the Crown Forest Sustainability Act; the Environmental Protection Act; the federal Fisheries Act; the federal Migratory Birds Act; the federal Species at Risk Act; and the existing provincial Endangered Species Act, to name but a few.

 

It did not attempt to explain that species at risk protection is also served by a large number of provincial programs and policies: the Conservation Land Tax Reduction Program, the Managed Forest Tax Incentive Program, M.N.R.’s Fish and Wildlife Management Programs; Natural Heritage protection policies under the Planning Act; and invasive species awareness and control programs, to name but a very few.

We believe there is already considerable legislation in place to prevent species from becoming endangered and significant protection of existing species at risk required by law on the Ontario landscape.

 

The weak link in the species protection chain (from preventing species from becoming endangered to recovering endangered species) is not deficiencies in legislation, but meaningful incentives for enhanced stewardship (and lack of community involvement in species recovery planning).

 

CRAA also believes that more would be accomplished to prevent species from becoming endangered in the first instance by restricting the scope of legislated protection to endangered species and their habitats, while preventing threatened species from becoming endangered through a robust stewardship program. Ontario species at risk will not be better protected under the proposed Act, and may well be more imperiled because the government has failed to consult adequately and meaningfully with an engaged public in the development of the legislation; ignored the reasoned and constructive advice of the land and resource management sectors; underestimated the costs of the legislation; and not provided the necessary legislative nor fiscal foundation for the critically important stewardship pillar. “

 

CRAA and Species at Risk

 

As the largest Non Governmental Organization in Ontario with a direct mandate to cold water migratory salmonids we represent upwards of 4000 anglers with a keen interest in the angling opportunities for Salmonids, as a group we have injected upwards of $3.5 million dollars in specific watersheds of Lake Ontario in relation to stewardship partners we are not aware of any other group with such tangible investments in habitat restoration, biodiversity and risk prevention of habitat loss and other related works programs in Ontario. We firmly believe that Bill 184 must be sent back to the stakeholders within each management zone once approved and that appropriate undertakings be done to support existing Management plans and that Bill 184 has the potentiality to negate these management directives some of which are well into the process.

 

These management plans address many of the proposed changes the bill would offer but in certain instances they would be diametrically opposed to this very bill. We believe the potentially exists that at some point these very same management plans could be declared “non productive” and that thousands of hours invested via steering committees has gone to vain and will potentially effect the current hierarchy of fisheries management in Ontario

 

We Urge you fulfill fiduciary obligations and allow this proposed bill to be sent to a broader scope of stakeholders for additional input and to restructure it so that it in fact does have potentially to make effective and positive change within the landscape of Ontario. In its current state Bill 184 will only cost tax payers millions of wasted dollars and push back Stewardship programs and biological diversity decades, something this province can not afford.

 

In closing, it is our expressed belief that this legislation is politically motivated, to quote a famous politician “politics is perception” and on the eve of a provincial election this program is designed to scurry votes as a piece of legislation that on the outward appearance sounds fantastic but once analysis by stakeholders is completed it appears to be nothing more then a “feel good” bill that shows us the current government required platform targets for the up coming election. We reiterate that in principle we support the concept but believe this bill required major amendments in order to achieve its desired result

 

Thank you for your time committee members and I’m happy to accept questions in my time allotment

 

Louis milo

VP CRAA

[outdoorguy61]

Thanks for posting this. Being at a distance with work, I remain very interested in many things relating to Ontarios outdoors.

 

And yes, this does sound poitically motivated. From what I can see of the current crew occupying Queens Park, we have been led astray with our dollars and our staff being far from adequate. Some of us are I suppose equally mercenary in wanting to get the job done, regardless of who is in power (my personal position).

 

outdoorguy61

[canadian_copper]

good work lou

[tonyb]

Louis, thank you for this information, and your continued efforts with CRAA and OFAH to be the watchdog for us anglers on issues such as this.

 

All I can say is that I agree with you 100% in this statement:

 

"In closing, it is our expressed belief that this legislation is politically motivated, to quote a famous politician “politics is perception” and on the eve of a provincial election this program is designed to scurry votes as a piece of legislation that on the outward appearance sounds fantastic but once analysis by stakeholders is completed it appears to be nothing more then a “feel good” bill that shows us the current government required platform targets for the up coming election. We reiterate that in principle we support the concept but believe this bill required major amendments in order to achieve its desired result"

 

Our government will continue to use the Province's Natural Resources as the proverbial scapegoat to enhance their 'just-in-time' appeal to the public before an election.

 

This makes me sick.

 

Tony

[aniceguy]

Tony very very true......Oct 10 we should see a change and the advocacy work in providing policy direction to the conservative caucus has lead me to beleive that the new premier come then John Tory should step up to the plate, if 20% of our policy advise comes to bare, we should see a leaner meaner MNR, that will change things big time...Tony maybe next week we can pop out one night for some pints with Aaron