Joint Comment on the Implementation of the Fisheries Act - Cumulative Effects
We are writing to express our serious concerns with your department’s approach to implementing the amended Fisheries Act and addressing cumulative effects. Many of our organizations have previously written to you about these concerns and we therefore request a meeting with you to discuss this issue.
In 2019 Parliament established a specific mandate to address cumulative effects associated with regulations and decision-making under the Act. Unfortunately, DFO is failing to follow the new legal requirement to consider cumulative effects when making policies and regulations, resulting in the ongoing degradation of fish habitat in Canada.
WCS Canada Comments on DFO Cumulative Effects Position Statement
We are pleased that the updated Fisheries Act (2019) has included renewed commitments to protect fish and fish habitat, strengthens the role of Indigenous knowledge informing habitat decisions, establishes a public registry, and includes recognition of principles of sustainability, the precautionary principle, ecosystem management, and consideration of cumulative effects.
We share the concern with DFO that failing to adequately consider cumulative effects will lead to continued loss of fish habitat in Canada, and we are pleased that DFO is working to better address cumulative effects. However, we have an overarching concern that the draft Position Statement falls short of providing clear and actionable guidance for the implementation of considering cumulative effects under the new Fisheries Act.
Therefore, this document contains: 1) a description of our concerns on the draft Position Statement and our corresponding recommended revisions to strengthen the Position Statement (p. 2), and 2) our recommendations for implementation in the Yukon and northern Ontario -- two landscapes where we have regional expertise (p. 5).
WCS Canada Comments on Proposed Updates to the Ontario Wetland Evaluation System (ERO No. 019-6160)
The proposed changes to the OWES are highly unlikely to meet the stated purpose by Ontario of increasing housing in Ontario. According to the ERO posting, “streamlining” the wetland evaluation process is necessary to support the construction of 1.5 million new housing units. However, a shortage of land isn’t the cause of the housing shortage in Ontario1.
WCS Canada Comments - Ontario’s Sustainable Bait Management Strategy - November 2019
We provide comments on Ontario’s Ministry of Natural Resources and Forestry (MNRF) Sustainable Bait Management Strategy. We support some of the proposed initiatives, including requirement of receipts and documentation for anglers using bait,
and the emphasis placed on education and training for industrial and recreational harvesters involved in the bait industry in Ontario. However, there is room for improvement to reduce the ecological risk that the bait industry poses to freshwater systems in Ontario.
WCS Canada Comments - Underwater Noise Management Plans Discussion Paper - March 2019
WCS Canada provides comments in response to Transport Canada's 2019 discussion paper, Reducing Underwater Vessel Noise through Underwater Noise Management Plans (UNMPs). We recommend that: i) UNMPs must be developed specifically for Arctic circumstances, ii) management at a fleet-level does not replace regional management or maximum noise limits, and iii) UNMPs need to be subject to regular review and continual refinement as our understanding of noise impacts continues to evolve.