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.
WCS Canada Comments - Strategic Policy for Bait Management in Ontario - June 2017
We strongly agree with the need to revise Ontario's live baitfish use policy and regulations and have been part of the Advisory Group and commenting on various proposals from the MNRF since 2013. This current draft offers the most comprehensive approach to addressing bait use and harvest in Ontario to date. The current draft does a good job of bringing together the disparate, but relevant components of bait use and harvest by anglers and commercial operators, primarily from an economic perspective. However, it fails to address the important ecological roles and values that baitfish play in freshwater systems. We do not support the reduced list for baitfish proposed by the MNRF, but are supportive of a number of other proposals in the draft including the creation of Bait Management Zones, movement restrictions for bait in and out of the Far North, and the prohibition of bait harvest, use, and storage in classes of provincial parks that have ecological integrity as their primary goal.
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