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WCS Canada Comments _Science & Research Parliamentary Committee Submission re Study on Top Talent, Research and Innovation_April 2022
WCS Canada provides comments to the Science & Research Parliamentary Committee regarding their Study on Top talent, research and innovation. This letter highlights the critical role of civil society scientists and the limited opportunities currently available to them through the Tri-Council pathways to advance science partnerships. We share some of the current opportunities and challenges we face in advancing scientific research to improve conservation outcomes that address government commitments and priorities for the environment and Indigenous Peoples. Finally, we provide recommendations on ways Canada can more fully integrate civil society science as crucial components of the “research ecosystem” in this country as a means of encouraging and retaining top talent on research and innovation.
WCS Canada Comments _Proposal for a Conservation Agreement for Boreal Caribou in Ontario -- ERO 019-4995 _ March 2022
WCS Canada provides comments on the Proposal for a Conservation Agreement for Boreal Caribou in Ontario -- ERO 019-4995. This includes a background and historical perspective on critical habitat protection for boreal caribou in Ontario and comments on three sections of the ERO notice: 1) Context 2) General Elements of the Agreement and 3) Table of Conservation Measures. We emphasize the importance of considering forest management activities over time as a key risk to boreal caribou and incorporating that in conservation measures.
Summary of Key Issues with the Draft Agreement to Conduct a Regional Assessment in the Ring of Fire Area and Recommendations
In 2021, the Government of Canada agreed to undertake a Regional Assessment (RA) of the Ring of Fire, an area of world‐class mineral potential located within the globally important Hudson Bay Lowland, under the federal Impact Assessment Act (IAA) at the request of WCS Canada and others. The Impact Assessment Agency of Canada (IAAC), in negotiation with the province of Ontario, developed a draft Agreement setting out the scope and form of the RA. As our comments below make clear, the draft Agreement fails to capitalize on the opportunity to undertake proactive planning for an area that is recognized internationally as a priority region for action on the global climate and biodiversity crises, and is the homeland of First Nations who are the only population living in the region. WCS Canada scientists have been actively working to understand the critical ecosystems and the species and services they support as well as approaches to conserving them, including with First Nation communities, for the past 15 years. We have applied our scientific knowledge of the area to inform our assessment and recommendations on the draft Agreement for the RA.
WCS Canada Comments_Draft Agreement to Conduct a Regional Assessment in the Ring of Fire (Reference Number: 80468)_January 2022
WCS Canada submits its comments to the Impact Assessment Agency of Canada (IAAC) regarding the draft Agreement for a Regional Assessment of the Ring of Fire Area. We make a number of recommendations around the need to address cumulative effects and governance. We identify key issues related to: 1) revising the goal to and objectives to address cumulative effects; 2) increasing the scope of the assessment to a “Regional Study Area” in which all human activities and climate change can be assessed through to the next 100 years; 3) including the current road proposals to the Ring of Fire; 4) expanding the assessment priorities to include peatlands and impacts to carbon storage and sequestration and a number of other ecological and social priorities; and, 5) specific recommendations on the composition and mandate of the Committee, and Advisory Groups, that will be conducting the Regional Assessment. We raise concerns about the process with First Nations and the lack of representation and inclusion to date.
WCS Canada Comments_Draft Project List Regulation Under The Environmental Act (ERO 019-4219_20220125)_ January 2022
WCS Canada submits comments to the Environmental Assessment Modernization Project Team of Ontario's Ministry of the Environment, Conservation and Parks. We recommend a complete overhaul of the proposed project list regulation in an expert-driven process based on four major concerns: 1) The project list is insufficiently inclusive of those most likely to have significant impacts; 2) There is no evidentiary basis for “thresholds” for inclusion on the project list; 3) The approach perpetuates lack of attention to cumulative effects in the EAA; and 4) There is no clear process that enables Ontarians to request designation of non-listed projects that warrant a Comprehensive EA.

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