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["Commenting on behalf of","Organization","Comment","Supporting links","Supporting documents","Comment approved"]
["on my own behalf",null,"Thank you for posting this on the registry and please continue this important work in sustaining and improving our natural environment and its natural wildlife. Can caribou be added?",null,null,"Yes"]
["on my own behalf",null,"Be careful what you do here - we only have one Earth.",null,null,"Yes"]
["on my own behalf",null,"The proposed government response statements seem to emphasize that there is an option of habitat destruction, as long as certain, unspecified conditions set by the Ontario government are met. This requirement is opaque and appears to favour developers and others who would stand to gain from removal of the protection of certain lands in Ontario. The response statements should emphasize instead that protection of the habitat of these species is of the utmost priority. If there are any extreme circumstances under which it would be permissible to disturb such habitats, then the response statements should clearly outline under what these conditions would be, in order to ensure transparency.",null,null,"Yes"]
["in my professional capacity, on behalf of my organization","8trees Inc.","We are interested in maintaining a dialogue between MECP and Species at Risk Implementation. We are developing a citizen science approach for data gathering and management that we hope this approach will help the government to gain up to date information regarding species observations and trends over time.\nIn addition, we are developing a walking (active) survey for SAR bats for small woodlands that will relate bat observations to habitat features of importance for protection. This can also be expanded to our citizen science approach.\nWe are here to help! and we give you permission to publish this comment in its entirety.","https://8trees.ca/","https://prod-environmental-registry.s3.amazonaws.com/public_uploads/2020-06/8Trees%20Incorporated%20Information.pdf","Yes"]
["on my own behalf",null,"I read the strategy for bats because I have watched the antics of little brown myotis for over 50 years, in Etobicoke and along Georgian Bay, and I am concerned because I have noticed a decline in observed numbers over time. I read the Blanding's turtle strategy because I have observed them in Etobicoke and witnessed their struggle for habitat in the Mimico Creek.\nI think that each of these two recovery strategies has been well thought through and appears to provide a good plan for the protection of these species at risk. I was interested reading about the different habitat requirements each animal needs to complete their life cycle. I appreciate that the intention is to try to protect and preserve the different habitat types to provide species their best chance to continue to live alongside their human neighbours. Thank you for pointing out that they all have low reproduction rates so that they are more vulnerable to rapid extinction from stressors such as habitat loss, disease, pesticides,  pollution, the decline of insects, etc, so that the need to act now to save the species is clear.\nThe Bat strategy on lines 374 - 395 will be critical to protect bats in the future. I appreciate that the government will continue to have conversations with industries in mining, aggregates, forestry, agriculture, wind power and with citizens with  \"nuisance\"\u009d concerns to educate about why bats are good for Ontario and work to find solutions for how to co-exist with them. Merlin Tuttle saved the bats in Arizona's Bracken Cave by explaining to people how bats benefit people. I hope that the Ministry of the Environment is given the mandate to undertake these initiatives.\nI wonder if a project for erosion control that has just been completed on the Mimico Creek would be different with inter-governmental co-operation under the direction of this Strategy ? While I understand the need for erosion control to protect properties close to the river, I was disappointed to see how much of the forest surrounding the river was clear cut. While a few trees in that zone have been planted, most of the tract cut was replaced with a gravel road, which extends on either side of the river. A large number of bat boxes have been installed along the gravel road in a manner that hints of trying to cover up the fact that the forest was not replaced. Your strategy points out on line 129 that \"clearcuts are generally avoided\" by bats. The armourstone installed along the shore does not look like much consideration was given to providing some natural habitat out of the way of human habitation for species like the Blanding's turtle to continue to find sites for egg laying. What will an impenetrable river's edge mean to the Blanding's turtle's survival? Would the department overseeing the Strategy be able to influence future projects for the benefit of both humans and species at risk? This project is typical of the chipping away and fragmentation of our natural spaces through development which individually have a small effect but in aggregate add up to big stresses on critical habitat and species at risk. Which is why the need for your Strategy exists and your impact could make a big difference.\nYour strategies depend on having a strong Endangered Species Act. I have been disappointed to read the number of permits granted since the April 2019 changes to the ESA came into force. When the ERO title lists \"permit to achieve an overall benefit to a species\", this is double speak for a permit to kill an endangered species (like logging of endangered butternut trees) or to destroy habitat critical to the survival of a species at risk. The proposed Strategies will succeed only if they are not frequently undermined by a weakened ESA.\nI hope that your Strategies are adopted and enforced, and that the science behind the survival of species at risk continues to guide public policy decisions.",null,"https://prod-environmental-registry.s3.amazonaws.com/public_uploads/2020-06/Creek%20pics.docx","Yes"]
["in my professional capacity, on behalf of my organization","St. Clair Region Conservation Authority","St. Clair Region Conservation Authority Response To the\nGovernment Response Statement to the Recovery Strategies for Blanding's Turtle, Eastern Whip-poor-will, Northern Bobwhite, Spotted Turtle, Little Brown Myotis, Northern Myotis, Tri-colored Bat, and White Wood Aster\nJune 1, 2020\nThe St. Clair Region Conservation Authority is located in southwestern Ontario and includes the Sydenham River watershed and smaller watersheds draining directly into southern Lake Huron, the St. Clair River and northeastern Lake St. Clair. Our position in the Carolinian Life Zone means we have a high percentage of Ontario's species at risk. This area also has a highly modified landscape with limited protected area, so it is essential to maintain and protect existing natural heritage features and the species at risk that inhabit them.  All species including species at risk, depend on functioning, resilient ecosystems to survive. The primary cause in most species' decline in the province is due to habitat loss and degradation. The ecosystems that provide habitat to all of our species provide numerous irreplaceable benefits such as air and water purification, soil stabilization, flood prevention and climate change mitigation. The Sydenham River watershed is home to the Blanding's Turtle, Eastern Whip-poor-will, Northern Bobwhite, Spotted Turtle, Little Brown Myotis, Northern Myotis, and the Tri-colored Bat.\nSCRCA fully endorses the Ontario government's Recovery Goals for the species found in our watershed and those that are not (White Wood Aster). SCRCA supports the long-term viability of existing local populations and, where biologically and technically feasible, supporting the increase in the distribution and abundance of the species by managing and restoring the species' habitat, improving habitat connectivity between local populations, reducing threats, and improving recruitment. Additionally, we support the filling knowledge gaps related to each of the listed species concerning their biology, habitat requirements, and the presence and severity of threats.\nAs a Conservation Authority located in Southwestern Ontario within the Sydenham River Watershed, SCRCA is well suited to assist the Ontario Government in achieving the Recovery Actions for the Blanding's Turtle, Eastern Whip-poor-will, Northern Bobwhite, Spotted Turtle, Little Brown Myotis, Northern Myotis, and the Tri-colored Bat. The Sydenham River Watershed is one of Canada's most biodiverse regions, with many local aquatic and terrestrial SAR. Implementing actions that benefit the listed SAR will further enhance the ecosystem for other local SAR and/or not-at-risk species.\nShould funding become available, SCRCA is more than willing to assist in the following aspects of Blanding's Turtle, Eastern Whip-poor-will, Northern Bobwhite, Spotted Turtle, Little Brown Myotis, Northern Myotis, and the Tri-colored Bat recovery in Ontario.\nManagement Actions\n1.\t(High) SCRCA is keen to work collaboratively with landowners, land managers, stakeholders, partners, and Indigenous communities and organizations, to develop and implement techniques and best management practices (BMP) to reduce threats to the species and their habitat. Working collaboratively, SCRCA would promote and implement where possible:\na.\talternatives to traditional development, where appropriate and feasible;\nb.\tmitigation techniques to address new road construction and road mortality, identifying and addressing existing road mortality hotspots, and using alternatives to traditional roadway construction techniques in sensitive habitats where possible (e.g., bridges over wetlands), where appropriate and feasible;\nc.\tstewardship activities to reduce disturbance to the species and their habitat (e.g., targeted signage to address local threats);\nd.\tencouraging and implementing techniques to reduce fishing by-catch;\ne.\tcontrolling invasive species in areas where they pose a direct threat to each species;\nf.\tmaintaining or enhancing habitat for Eastern Whip-poor-will and other aerial insectivores and their insect prey at both local and landscape levels;\ng.\tpromoting the implementation of policies and programs that promote beneficial insects and reduce light pollution and the pollutants that contribute to climate change; and,\nh.\tworking with local municipalities, conservation authorities and other relevant agencies to implement water management plans that minimize impacts to the species and its habitat.\n2.\tSCRCA is keen to support and work with local landowners, land managers, stakeholders, organizations, government agencies, and Indigenous communities and organizations to develop and implement coordinated habitat management plans to increase habitat suitability and connectivity, and create, enhance and restore habitat at priority sites.\na.\tSCRCA has strong working relationships with Upper Thames River Conservation Authority and Salthaven Wildlife Rehabilitation and Education Centre that have boosted the local head-starting program for local at risk turtle species in Southwestern Ontario.\n3.\tSCRCA is keen to implement, evaluate, adapt and improve techniques to reduce Blanding's turtle, Spotted Turtle, and other SAR turtle nest predation and improve recruitment, including methods such as nest caging and head-starting in areas where these activities are deemed necessary and appropriate (i.e., recruitment is believed to be insufficient to maintain viable populations).\n4.\t(High) SCRCA is keen to work collectively with industry (e.g., mining, aggregates, forestry, problem/nuisance wildlife removal, agriculture, wind power) develop, implement, evaluate and promote best management practices to minimize the impacts of industry activities and operations on Little Brown Myotis, Northern Myotis and Tri-colored Bat and their habitat.\n5.\t(High) SCRCA is keen to work collaboratively with Walpole Island First Nation, landowners, land managers, and researchers to develop, implement and evaluate management plans and best management practices to maintain or improve the quality of Northern Bobwhite habitat and viability of populations at existing sites.\n6.\tSCRCA is keen to work with local landowners, municipalities and community partners to strategically secure SAR habitat and encourage long-term protection through existing land securement and stewardship programs and/or land securement agencies, including land that would support improved habitat connectivity.\na.\tSCRCA has worked with local landowners and stewardship groups in our watershed for over 20 years, implementing over 615 stewardship projects that benefit many SAR species. Many of these stewardship projects have been supported by the Ontario Species at Risk Stewardship Program (2008-2018).\n7.\tSCRCA is also keen to support and work collaboratively with relevant government, law enforcement agencies and other partners to develop and implement coordinated strategies to address the threat of illegal collection.\nResearch and Monitoring\n8.\t(High) Where necessary and/or possible, SCRCA is keen to work collaboratively with local landowners, land managers, industry stakeholders, organizations, government agencies, partners and Indigenous communities and organizations to develop and implement a standardized survey and monitoring programs for Blanding's Turtle, Spotted Turtle, Eastern Whip-poor-will, Little Brown Myotis, Northern Myotis, and Tri-colored Bat that include:\na.\tmonitoring distribution and abundance of the species at representative sites across its range in Ontario to identify and track changes in population abundance over time;\nb.\tassessing species' presence at sites lacking recent observations (including historical sites and extirpated sites where suitable habitat remains) and refining knowledge of the local and regional distribution of these listed species at risk in Ontario; and,\nc.\tmonitoring emerging and existing threats to the species; and, encouraging participation in citizen science data collection programs (e.g., iNaturalist).\n9.\t (High) SCRCA is keen to support research to evaluate the effectiveness of threat mitigation techniques, recovery approaches and best management practices, including:\na.\ttechniques to mitigate impacts of activities;\nb.\tapproaches for habitat creation, restoration and improvement;\nc.\ttechniques for salvage and translocation; and,\nd.\ttechniques for improving recruitment (e.g., nest protection and incubation, head-starting, predator exclusion).\n10.\tSCRCA will support investigations into and will continue to monitor the severity and potential impacts of threats to local populations such as invasive species, human-subsidized predators, fishing by-catch, illegal collection, pollution and climate change.\n11.\tSCRCA supports future research on species' biology, ecology, habitat use and genetics where knowledge gaps persist, such as:\na.\tminimum habitat and population requirements to ensure local population viability (e.g., suitable habitat size, number of mature individuals);\nb.\thabitat needs and use for various life stages (e.g., nesting, feeding, hibernating);\nc.\tpopulation genetics and demographics across the species' range;\nd.\tinvestigate the need for and feasibility of augmentation or reintroduction of Northern Bobwhite populations,\ne.\tfurther refine understanding of the Eastern Whip-poor-will's ecology and habitat characteristics; and,\nf.\teffects of changes in precipitation, water levels, and extreme weather on local habitat availability and individual survival (e.g., flooding of nests along shorelines).\n12.\t As appropriate, SCRCA encourages the recording, sharing and transfer of Traditional Ecological Knowledge on these species at risk, where it has been shared by communities, to increase knowledge of the species and support future recovery efforts.\nAwareness and Stewardship\n13.\tSCRCA is keen to promote public awareness of local species at risk, including their status and protection under the ESA, and engage the public in stewardship education and implementation. This may include:\na.\tdeveloping interactive social media and social marketing campaigns to promote species at risk stewardship and reduce threats;\nb.\tcoordinate with other species at risk initiatives, where appropriate;\nc.\tworking collaboratively with land owners, land managers, municipalities, the public, and other stakeholders to increase their awareness of local species at risk and how to reduce impacts to the species; and,\nd.\teducating the public on what to do if they encounter an injured individual.\nSCRCA supports the recovery of the Blanding's Turtle, Eastern Whip-poor-will, Northern Bobwhite, Spotted Turtle, Little Brown Myotis, Northern Myotis, Tri-colored Bat, and White Wood Aster in the Sydenham River Watershed and beyond. We are keen to assist where we are able and implement as many of the recovery actions as feasible.",null,null,"Yes"]
["in my professional capacity, on behalf of my organization","St. Clair Region Conservation Authority","St. Clair Region Conservation Authority Response \nTo the Government Response Statement to the Recovery Strategy for the Spiny Softshell in Ontario \nJune 18, 2020 \nThe St. Clair Region Conservation Authority is located in southwestern Ontario and includes the Sydenham River watershed and smaller watersheds draining directly into southern Lake Huron, the St. Clair River and northeastern Lake St. Clair. Our position in the Carolinian Life Zone means we have a high percentage of Ontario's species at risk. This area also has a highly modified landscape with limited protected area, so it is essential to maintain and protect existing natural heritage features and the species at risk that inhabit them.  All species including species at risk, specifically, the Spiny Softshell, depend on functioning, resilient ecosystems to survive. The primary cause in most species' decline in the province is due to habitat loss and degradation. The ecosystems that provide habitat to all of our species provide numerous irreplaceable benefits such as air and water purification, soil stabilization, flood prevention and climate change mitigation.  \nSCRCA fully endorses the Ontario government's Recovery Goal for the Spiny Softshell of supporting the long-term viability of existing local populations and, where biologically and technically feasible, supporting the increase in the distribution and abundance of the species by managing and restoring the species' habitat, improving habitat connectivity between local populations, reducing threats, and improving recruitment. \nAs a Conservation Authority located in the heart of known Spiny Softshell habitat in Southwestern Ontario (the Sydenham River Watershed), SCRCA is well-suited to assist the Ontario Government in achieving the Recovery Actions for the Spiny Softshell.  \nShould funding become available, SCRCA is more than willing to assist in the following aspects of Spiny Softshell recovery in Ontario:  \nManagement Actions\n(High) SCRCA is keen to work collaboratively with landowners, land managers, stakeholders, partners, and Indigenous communities and organizations, to develop and implement techniques and best management practices (BMP) to reduce threats to the species and their habitat. Working collaboratively, SCRCA would promote and implement where possible: \n- alternatives to traditional development, such as using natural forms of shoreline stabilization rather than hardening shorelines with \"rip-rap\" or stone walls, where appropriate and feasible;  \n- mitigation techniques to address new road construction and road mortality, including constructing turtle eco-passages (e.g., fencing and tunnels), identifying and addressing existing road mortality hotspots, and using alternatives to traditional roadway construction techniques in sensitive habitats where possible (e.g., bridges over wetlands), where appropriate and feasible; \n- stewardship activities to reduce disturbance to the species and their habitat (e.g., targeted signage to address local threats);  \n- encouraging and implementing techniques to reduce fishing by-catch; \n-controlling invasive species in areas where they pose a direct threat to Spiny Softshell; and, \n- working with local municipalities, conservation authorities and other relevant agencies to implement water management plans that minimize impacts to the species and its habitat, particularly with respect to flooding of nesting habitat during the nesting and incubation period and water drawdowns during the hibernation period. \nSCRCA is keen to support and work with local landowners, land managers, stakeholders, organizations, government agencies, and Indigenous communities and organizations to develop and implement coordinated habitat management plans to increase habitat suitability and connectivity, and create, enhance and restore habitat at priority sites.  \nSCRCA has strong working relationships with Upper Thames River Conservation Authority and Salthaven Wildlife Rehabilitation and Education Centre that have boosted the local head-starting program for Spiny Softshell in Southwestern Ontario. \nSCRCA is keen to implement, evaluate, adapt and improve techniques to reduce nest predation and improve recruitment, including methods such as nest caging and head-starting in areas where these activities are deemed necessary and appropriate (i.e., recruitment is believed to be insufficient to maintain viable populations). \nSCRCA has over 3 years of experience implementing nest caging and head-starting methods to reduce nest predation and improve recruitment in the Sydenham River Watershed.  \nIn 2018 alone, SCRCA collected 282 Spiny Softshell eggs to head-start and return to their respective nest locations.  \nSCRCA is keen to work with local landowners, municipalities and community partners to strategically secure Spiny Softshell habitat and encourage long-term protection through existing land securement and stewardship programs and/or land securement agencies, including land that would support improved habitat connectivity. \nSCRCA has worked with local landowners and stewardship groups in our watershed for over 20 years, implementing over 615 stewardship projects that benefit many SAR species, including Spiny Softshell. Many of these stewardship projects have been supported by the Ontario Species at Risk Stewardship Program (2008-2018).  \nSCRCA is also keen to support and work collaboratively with relevant government, law enforcement agencies and other partners to develop and implement coordinated strategies to address the threat of illegal collection. \nResearch and Monitoring\n(High) Where necessary and/or possible, SCRCA is keen to work collaboratively with local landowners, land managers, industry stakeholders, organizations, government agencies, partners and Indigenous communities and organizations to develop and implement a standardized survey and monitoring programs that include:\n- monitoring distribution and abundance of the species at representative sites across its range in Ontario to identify and track changes in population abundance over time; \n- assessing species' presence at sites lacking recent observations (including historical sites and extirpated sites where suitable habitat remains) and refining knowledge of the local and regional distribution of Spiny Softshell in Ontario; \n- monitoring emerging and existing threats to the species; and, encouraging participation in citizen science data collection programs (e.g., iNaturalist). \n- (High) SCRCA is keen to support research to evaluate the effectiveness of threat mitigation techniques, recovery approaches and best management practices, including:  \n- techniques to mitigate impacts of activities, such as shoreline development and dam construction and operation, on nesting sites;  \n- approaches for habitat creation, restoration and improvement; \n- techniques for salvage and translocation; and,  \n- techniques for improving recruitment (e.g., nest protection and incubation, head-starting, predator exclusion).  \nSCRCA will support investigations into and will continue to monitor the severity and potential impacts of threats to local populations such as invasive species, human-subsidized predators, fishing by-catch, illegal collection, pollution and climate change.  \nSCRCA supports future research on species' biology, ecology, habitat use and genetics where knowledge gaps persist, such as:\n- minimum habitat and population requirements to ensure local population viability (e.g., suitable habitat size, number of mature individuals);  \n- habitat needs and use for various life stages (e.g., nesting, feeding, hibernating); \n- population genetics and demographics across the species' range; and,  \n- effects of changes in precipitation, water levels, and extreme weather on local habitat availability and individual survival (e.g., flooding of nests along shorelines).  \nAs appropriate, SCRCA encourages the recording, sharing and transfer of Traditional Ecological Knowledge on Spiny Softshell, where it has been shared by communities, to increase knowledge of the species and support future recovery efforts. \nAwareness and Stewardship\nSCRCA is keen to promote public awareness of Spiny Softshell, including its status and protection under the ESA, and engage the public in Spiny Softshell stewardship. This may include:\n- developing interactive social media and social marketing campaigns to promote Spiny Softshell stewardship and reduce threats such as accidental mortality and illegal collection. Coordinate with other species at risk turtle initiatives where appropriate; \n- working collaboratively with landowners, land managers, municipalities, the public, and other stakeholders to increase their awareness of Spiny Softshell and how to reduce impacts to the species; and, \n- educating the public on what to do if they encounter an injured turtle or a nest in a high-risk area. \nSCRCA supports the recovery of the Spiny Softshell in the Sydenham River Watershed and beyond. We are keen to assist where we are able and implement as many of the recovery actions as feasible.",null,null,"Yes"]
["in my professional capacity, on behalf of my organization","Ontario Federation of Anglers and Hunters","Subject: ERO # 019-1749 Developing government response statements for nine species at risk under the Endangered Species Act, 2007\nThe Ontario Federation of Anglers and Hunters (OFAH) is Ontario's largest, non-profit, fish and wildlife conservation-based organization, representing 100,000 members, subscribers, and supporters, and 725 member clubs. We have reviewed the draft Government Response Statement (GRS) to the Recovery Strategy for the Northern Bobwhite in Ontario and offer the following comments for consideration.\nGovernment's Recovery Goal\nThe OFAH believes that the ultimate recovery goal should be to restore self-sustaining populations of wild Northern Bobwhite on not only Walpole Island, but also the mainland. Increasing habitat and protecting the current population of Northern Bobwhite is not enough to consider them recovered. This is especially true given the uncertainty about whether or not Northern Bobwhite still persist. \nMuch of the content of the GRS is contingent on Northern Bobwhite persisting on Walpole Island, even though birds have not been observed since 2013 at which time the population was on a declining trajectory towards extirpation. It is our hope that Walpole Island continues to support a Northern Bobwhite population. However, if the population survey recommended in the GRS yields no positive results, a major rethink will be needed to ensure a plan that leads to the recovery of Northern Bobwhite in Ontario.\nIn the recovery goal, the government states that it supports investigating the necessity and feasibility of potential augmentation and reintroduction for the long-term persistence of Northern Bobwhite. The OFAH is supportive of reintroduction if the current population is no longer sufficient to support population growth and expansion or has been extirpated. We would suggest that the Ministry of Environment, Conservation and Parks (MECP) develop a strategy to guide augmentation of Northern Bobwhite populations that clearly lays out key decision points such as: threshold needed to  take this action (e.g. number of remaining birds dips too low to support the population); location of the most genetically similar birds and how can Ontario obtain them; whether the intention is to have introduced birds crossbreed with existing birds or to attempt to create a separate population; and, most suitable locations for introductions. The first step to any of the actions or recovery goals will be to determine the size of the current population and whether it is capable of surviving and repopulating effectively without the introduction of outside birds.\nGovernment-led Actions\nInvasive species\nThe government-led actions include utilizing the Invasive Species Act and Ontario Invasive Species Strategic Plan to control invasive species that threaten Northern Bobwhite. The OFAH agrees that this is an essential part of restoring Northern Bobwhite populations but has concerns regarding its practical implementation. Phragmites management and removal is a long and intensive undertaking that requires an integrated pest management approach including cutting, burning, and the use of herbicides. The effective herbicide for phragmites isn't currently permitted for use over water; however, phragmites typically occurs near water. To effectively utilize herbicide, a Pest Management Regulatory Agency label expansion would be required to permit use over water (either permanently or through an emergency expansion). In areas where Phragmites threatens Northern Bobwhite habitat, MECP needs to take thorough measures to ensure that it is actively managed if there is any hope to improve habitat.  As this is considered a government-led action, will MECP be funding the removal of Phragmites in Northern Bobwhite range? Additionally, if the ultimate goal of Northern Bobwhite recovery includes a range expansion, MECP will need to consider Phragmites control in candidate areas for population expansion.\nPredators\nThe GRS mentions the various predators of Northern Bobwhite in their current and native range, including raccoons, foxes, coyotes, and domestic cats; however, there are no listed actions associated with predator control except for education about predator impacts. The only mention of predators in the Actions is to assess predation rates, which falls woefully short of what is required for Bobwhite recovery. It is our contention that if the population of Northern Bobwhite was headed towards extirpation in 2013, then it is likely that any predation would be very problematic for the population. The MECP should consider working with area trappers and the Walpole Island First Nation to increase the trapping and/or hunting of predators in the areas around where Northern Bobwhite are found.\nThe OFAH is also concerned about the absence of any mention of wild pigs or feral swine in regard to invasive species or predation pressure on Northern Bobwhite. Ontario is facing an increasing threat from invasive wild pigs becoming established and spreading throughout the province. Nesting success of Northern Bobwhite has been shown to be negatively impacted by wild pigs across the United States (Bevins et al. 2014). Without a tangible management plan to prevent wild pigs from becoming established in Ontario, any recovery efforts for Northern Bobwhite would be functionally useless. The OFAH recommends that the Ontario government include the eradication of wild pigs in the government-led actions of the GRS.\nGame bird hunting preserves\nGame bird hunting preserves provide important opportunities for upland bird hunters, including the ability to train and use highly specialized bird dogs. Pen-reared Northern Bobwhite are an important hunting opportunity for Ontarians and the OFAH is encouraged to see the MECP include the continuation of permitting for them. These hunting preserves are also offering an opportunity for hunters to learn about and value Northern Bobwhite in a much more meaningful way than most species at risk are valued. It was demonstrated through the Wild Turkey and elk reintroduction programs that hunters who have vested interests in healthy game species populations are invaluable partners in successful restoration. The OFAH views game bird hunting preserves as key partners in Northern Bobwhite recovery both through familiarization and, potentially, as reintroduction sites. In the event that introduction of Northern Bobwhite is necessary to recover the Ontario population, is there a way that the release of Northern Bobwhite for hunting purposes could be integrated into the restoration process? This could include using birds from genetically similar U.S. states as releases in areas close to Walpole Island to ensure that any birds that escape can contribute to the population and supplement the genetics, instead of the worry that pen-reared birds could weaken the genetic integrity of the wild population.\nGovernment-supported Actions\nThe majority of the actions needed to recover Northern Bobwhite in Ontario are \"government-supported\"\u009d rather than \"government-led\"\u009d and as such, there is no clear framework for ensuring that these actions will take place in the needed cohesive and coordinated manner. The GRS puts the onus on partners to bring forth projects in line with the government-supported actions, an approach that may or may not result in these actions being undertaken.\nThe recovery of Northern Bobwhite is entirely dependent on direct involvement and stewardship from Walpole Island First Nation (WIFN). Involvement and leadership from the Indigenous community will be required to implement the majority of actions outlined in the GRS. We understand that WIFN has already done extensive habitat-related work to reverse biodiversity loss (e.g. Walpole Island Land Trust) and we applaud them. The recovery of Northern Bobwhite presents an opportunity to build on these existing stewardship activities and create an opportunity for strong collaboration. The OFAH recommends that the recovery of Northern Bobwhite build upon the successful model that resulted in Ontario's robust Wild Turkey populations. A key component of this success was the formation of working groups that included both governmental and non-governmental partners. Such a working group for Northern Bobwhite would provide important direction and cohesion among both government-supported and -led activities. Having the working group led by Walpole Island First Nation would start the initiative off with a wealth of existing local and ecological knowledge. Additional members of the working group could include MECP, the Ministry of Natural Resources and Forestry (MNRF), the Ministry of Agriculture, Food and Rural Affairs (OMAFRA), the OFAH, the Ontario Federation of Agriculture, and ALUS Canada.  \nSurvey and Monitoring\nThe OFAH agrees with the assessment that surveying and monitoring is a high priority for the restoration of Northern Bobwhite populations. The Recovery Strategy for Northern Bobwhite in Ontario indicates that the ability for the current population of Northern Bobwhite to sustain itself and to then increase in abundance is unknown. As this is currently the only approved source population for Ontario, due to genetic divergence from neighbouring jurisdictions, it is essential to complete a population assessment to determine the feasibility of restoration. Generating a population estimate and genetic information on Ontario's population will allow managers to determine if the existing population is capable of effectively reaching carrying capacity on Walpole Island on its own. This information is critical in moving forward with restoration efforts, as it determines the best course of action early on in the process. If it is determined that the current population is too small to repopulate Walpole Island and the mainland, then it will be necessary to consider how to best introduce birds from outside populations. Understanding the status of the current Walpole Island population will also change what organizations will be key partners moving forward with restoration.\nResearch\nUnderstanding the genetics of the existing Walpole Island population is a critical piece in the above-mentioned population status which determines whether the population will be able to repopulate Ontario without outside introductions. If this research determines that the current Walpole Island population is not large or genetically diverse enough to restore the population, then the MECP must support investigating the need for augmentation of Northern Bobwhite populations. Ontario has examples of success in restoring populations by introducing animals from external sources, such as Wild Turkey and elk. If the current population of Northern Bobwhite is found to be too small to survive, then the MECP should be ready to initiate a reintroduction project. A major component of this will be to locate a suitable source population and begin to build relationships with the relevant US States where those populations exist.\nManagement and Habitat Protection\nPrior to the start of any additional management and habitat protections, the MECP should work with WIFN to determine how Northern Bobwhite protections will impact their community and how those protections will be enforced. Additionally, the existing habitat work that WIFN has done should be leveraged in planning new habitat projects.\nThere are multiple actions under this objective that indicate that the government will assist landowners with high level habitat management such as developing best management practices, protocols, and strategies but there is very little incentive for land owners to implement these. In order to achieve habitat restoration for Northern Bobwhite, the MECP will need to use the Species at Risk Stewardship Program to help subsidize the costs associated with landowners transforming their land. This money can be leveraged by utilizing programs such as ALUS Canada to provide an incentive for farmers to create or improve Northern Bobwhite habitat on their farms. The MECP should also consider new programs to incentivize non-farm landowners to create species at risk habitat. These actions should be done in conjunction with Environment and Climate Change Canada (ECCC), as they also have requirements to protect Northern Bobwhite habitat under the Species at Risk Act. As ECCC develops their action plan for Northern Bobwhite, the MECP should be involved to align actions being planned and taken.\nOutreach and Awareness\nThe GRS does not indicate that any of the outreach and awareness actions are high priority but many of the required actions in the other categories require public outreach and awareness. The OFAH believes that the MECP should improve their outreach regarding certain aspects of Northern Bobwhite restoration, which will also have benefits for other species at risk. Encouraging landowners to create and restore habitat will require a comprehensive outreach plan that includes; best options for habitat creation, funding options for projects, ways to support Northern Bobwhite while maintaining their farming/land use practices, and any ways that they can report the status of their local Northern Bobwhite populations. Additionally, outreach and awareness will be critical to address predation issues. Free-ranging cats are a significant threat to the restoration of Northern Bobwhite and the public needs to be aware of the implications associated with allowing their cats to be outside and the risk of feeding feral cats instead of contacting an animal control company to remove them. Education about wild pigs will also be extremely important to recovering Northern Bobwhite in Ontario. Landowners in the Walpole Island area will need to be able to identify and report sightings of wild pigs so that MNRF can act quickly to remove them from the landscape. Rapid response to sightings is critical in preventing them from becoming established, and landowners have a role to play in that. The MECP should work with the MNRF and OMAFRA to educate farmers and landowners in the Walpole Island area in how to prevent pig escapes, detect the presence of pigs on the landscape, and report them.\nFar-reaching benefits\nThe actions taken to recover Northern Bobwhite in Ontario will have net benefits well beyond the species itself. By restoring habitat such as tallgrass prairie, savanna, and open early-successional forests, all the species that rely on these areas will benefit. This will include game species such as ruffed grouse, cottontail, and European hare but also have net biodiversity benefits by improving songbird, small mammal, insect, reptile, and amphibian communities. The same will hold true for actions taken to control invasive plant species and non-native predators such as free-ranging cats and wild pigs. Restoring Northern Bobwhite habitat and populations provides an opportunity to showcase the benefit of landscape level species management and make significant improvements to habitat and wildlife in southern Ontario.\nThe OFAH believes that we can be a key partner in many aspects of Northern Bobwhite recovery through the Invading Species Awareness Program, our experience in restoring Wild Turkey and elk to Ontario, and our ability to leverage to significant volunteer capacity that exists in the hunting community. We look forward to providing continuing input. Thank you for your consideration of our comments.",null,"https://prod-environmental-registry.s3.amazonaws.com/public_uploads/2020-06/ERO%20019-1749%20Northern%20Bobwhite%20GRS-jun24-20.pdf","Yes"]
["in my professional capacity, on behalf of my organization","Canadian Herpetological Society","Re: Comments on the Draft Government Response Statements to the Recovery Strategy for the Blanding's Turtle, Spotted Turtle and Spiny Softshell in Ontario\nThank you for providing an opportunity to review these Government Response Statements (GRS). These comments represent our organizationâ€™s official submission. Overall, these GRS are well written and the recommended actions generally address the threats that these three turtles face in Ontario. \nSpotted Turtle\nThis GRS is well written and the recommended actions generally address the threats that the Spotted Turtle faces in Ontario.\nThe Spotted Turtle has declined dramatically in Ontario and as the GRS states the species has only been confirmed at only 25 sites in the province in the recent past. As such we fully support the recovery goal \"to support the long-term viability of existing local populations and, where biologically and technically feasible, support increases in their distribution and abundance, by mitigating threats, maintaining or increasing suitable habitat, improving habitat connectivity between local populations, and improving recruitment.\"\u009d\nWe are in general agreement with the priority recovery actions identified in the GRS. Specific comments on those actions:\nâ€¢\tWe emphasize the importance of the Government led action to \"Continue to protect Spotted Turtle and its habitat through the ESA.\"\u009d Unfortunately, implementation of the ESA has still resulted in habitat destruction that is insufficiently offset. Protecting the habitat of Spotted Turtle should mean not allowing destruction of Spotted Turtle habitat. Otherwise, the species will continue to decline by death by a thousand cuts.\nâ€¢\tWe suggest that Action 9 (increasing recruitment through nest-caging and head-starting) not be ranked as High priority because of the large costs (in time, and effort) for a relatively small (and untested) effect on population viability. We agree that in some cases, recruitment may not be high enough for populations to be viable, but preventing threats to adults (e.g. habitat loss) is more pressing than low recruitment.\nâ€¢\tWe suggest that Action 10 (working to increase the amount of suitable habitat where appropriate) should be a High priority.\nâ€¢\tWe suggest Action 11 (securing and protecting habitat) is changed to High priority, given that protecting habitat will have a large effect on meeting the recovery goal of supporting the long-term viability of existing populations. Protecting adults and their habitat is the most effective way to meet this recovery objective.\nâ€¢\tAction 13 specifically mentions turtle crossing signs. Research suggests crossing signs are not effective (e.g. Seburn and McCurdy-Adams 2019). Reducing the speed limit in high risk areas is likely more effective. Traveling at a slower speed gives drivers more time to see wildlife on roads.\nâ€¢\tWe suggest adding a statement on encouraging participation in citizen science data collection programs (e.g. iNaturalist), such as is found in the GRS for the Spiny Softshell. The relevant section would be Research and Monitoring Focus Area (L195-257).\nBlanding's Turtle\nThe GRS is mostly well written, and the recommended actions will help address the threats to Blanding's Turtle in Ontario.\nWe fully support the recovery goal to \"support the long-term viability of existing local populations in Ontario and, where biologically and technically feasible, support increases in their distribution and abundance, by reducing threats, managing and restoring suitable habitat, improving habitat connectivity between populations, and improving recruitment\".\nWe are in general agreement with the priority recovery actions identified in the GRS. Specific comments on those actions:\nâ€¢\tWe emphasize the importance of the Government led action to â€œContinue to protect Blanding's Turtle and its habitat through the ESA. Unfortunately, implementation of the ESA has still resulted in habitat destruction that is insufficiently offset. Protecting the habitat of Blanding's Turtle should mean not allowing destruction of Blanding's Turtle habitat. Otherwise, the species will continue to decline by death by a thousand cuts.\nâ€¢\tThe first Government-led Action (\"Continue to protect Blanding's Turtle and its habitat through the ESA. Continue to implement the species-specific habitat description for Blanding's Turtle\") will be unfeasible if there is a continued exemption of the Endangered Species Act for the forestry industry (e.g. https://ero.ontario.ca/notice/019-1620). More than half of the species' range in Ontario overlaps with forestry sectors on Crown land (COSEWIC 2016).\nâ€¢\tL170-171: There is a typo (\"at the northern extent its range\" should be \"at the northern extent of its range\").\nâ€¢\tL215-217 may have a typo where \"through the NHIC\"\u009d is repeated twice when the first mention should be \"through the Rare species of Ontario project in iNaturalist\".\nâ€¢\tL327: There is a typo where \"does not increase risk the species\" should be \"does not increase risk to the species.\nâ€¢\tGiven that Blanding's Turtle is especially sensitive to increases in adult mortality from road and rail mortality, we fully support the Action 8 (high priority) of implementing and evaluating best management practices for mitigation techniques to address new road construction and road mortality.\nâ€¢\tAction 12 specifically mentions turtle crossing signs. Research suggests crossing signs are not effective (e.g. Seburn and McCurdy-Adams 2019). Reducing the speed limit in high risk areas is likely more effective. Traveling at a slower speed gives drivers more time to see wildlife on roads.\nâ€¢\tBoth the Spotted Turtle GRS (L209-213) and Spiny Softshell GRS (L256-259) include the sentence \"...recovery efforts... may be further improved by working with interested Indigenous communities and Knowledge Holders to understand Traditional Ecological Knowledge of the species and encourage its integration into collaborative management actions.\"\u009d The same section in the Blanding's Turtle GRS (L248-262) does not include this sentence.\nâ€¢\tThe Spiny Softshell GRS Action 6 (L273-274) specifically mentions \"encouraging participation in citizen science data collection programs (e.g., iNaturalist).\", but no Blanding's Turtle GRS actions mention this. The relevant section would be the Research and Monitoring Focus Area (L244-307).\nâ€¢\tThe Spotted Turtle GRS (L124-125) specifically mentions the risk of disease transmission from the release of non-native pet turtles, such as the Red-eared Slider. This risk should be added to the Blanding's Turtle GRS. \nSpiny Softshell\nThe GRS for Spiny Softshell is well written and addresses the major threats to this species. \nWe support the stated recovery goal to support the long-term viability of existing local populations and, where biologically and technically feasible, support increases in the distribution and abundance of the species by managing and restoring the species'  habitat, improving habitat connectivity between local populations, reducing threats, and improving recruitment.\"\u009d\nSpecific comments on actions:\nâ€¢\tAction 1 (High Priority) to develop and implement techniques and best management practices to reduce threats to the species and its habitat addresses many of the major threats, but not disturbance and mortality from boat traffic. Considering that injury and mortality from boat collisions is listed as a significant threat to Spiny Softshell (in the GRS and in the recovery strategy), we suggest adding a sub-action to address this threat.\nâ€¢\tL215 may have a typo: \"where possible (e.g., bridges over wetlands)\"\u009d is followed by \"where appropriate and feasible\"\u009d. The sentence should end with \"where possible (e.g., bridges over wetlands).\nâ€¢\tThe Spotted Turtle GRS (L124-125) specifically mentions the risk of disease transmission from the release of non-native pet turtles, such as the Red-eared Slider. This risk should be added to the Spiny Softshell GRS. \nWe look forward to seeing the final version of these documents.\nLiterature cited\nSeburn, DC and H McCurdy-Adams. 2019. Do turtle warning signs reduce roadkill? Canadian Field-Naturalist 133:216-220. https://doi.org/10.22621/cfn.v133i3.2279",null,null,"Yes"]
["in my professional capacity, on behalf of my organization","Ontario Rivers Alliance","The Ontario Rivers Alliance (ORA) is a not-for-profit grassroots organization acting as a voice for several stewardships, organizations, private and Indigenous members who have come together to protect, conserve and restore Ontario riverine ecosystems.\nThe province is proposing Government Response Statements (GRSs) outlining the actions government will take and support to protect and recover nine species at risk in Ontario.  Blanding's Turtle Eastern Whip-poor-will, Little Brown Myotis, Northern Bobwhite, Northern Myotis, Spiny Softshell Spotted Turtle, Tri-colored Bay and White Wood Aster.\nThe ORA supports all of the draft GRSs under this Environmental Registry posting.  The recommended actions all seem to be in alignment with each speciesâ€™ recovery and if implemented properly should play a key role in protecting these species and Ontario's biodiversity.  \nHowever, ORA objects to one statement that appears in all of the draft recovery strategies under \"Implementing Actions\", which states,\"Implementation of the actions may be subject to changing priorities across the multitude of species at risk, available resources and the capacity of partners to undertake recovery activities\"\u009d.  This single sentence places all of the above GRSs and recovery strategies in a state of uncertainty.\nA perfect recent example was in the recent Environmental Registry posting, ERO-019-1620 “ Proposed amendment to a regulation under the Endangered Species Act (ESA), 2007, relating to Forest Operations in Crown Forests.  This proposal amounted to a blanket exemption to the ESA for logging activity in Crown Forests.  Yet the ERO in its \"Proposal details\" states, \"Ontario is committed to providing strong protections for species at risk and improving outcomes by modernizing and improving the effectiveness of the Endangered Species Act, as committed to in our Made-in-Ontario Environment Plan\".  This statement is misleading when instead the proposed amendment would set aside the ESA for an entire industry when logging on Crown land. \nThis ERO proposal describes the GRSs as providing \"stringent protections for species at risk and their habitats under the Endangered Species Act\", but how stringent are these protections when the legislation can be so easily set aside?  This means that protection and recovery under the ESA is uncertain for all species at risk.\nORA objects to this above statement being included in the GRS, and strongly recommends that it be removed.",null,"https://prod-environmental-registry.s3.amazonaws.com/public_uploads/2020-06/2020-06-28-ORA-GRS-ESA.pdf","Yes"]