Thank you, Mr. Chair.
Good afternoon, ladies and gentlemen. The 100,000 individual anglers and hunters and 670 member clubs that make up the Ontario Federation of Anglers and Hunters membership and subscribers are among the most committed fish and wildlife conservationists in Canada. We have provided you, ladies and gentlemen, with a written submission. I'm not going to go through that written submission in its entirety. I hope you will be able to at some point. If you have at that time additional questions or if we can be of additional assistance, please feel free to contact us at any time.
Our conservation legacy includes populations of abundant, healthy fish and wildlife fully restored from near extinction. Through voluntary efforts and lobbying for effective conservation laws and enforcement, many species that were once almost extirpated are again common today, species such as wild turkey, moose, wood ducks, beavers, Canada geese, and eastern bluebirds, to name a few. Importantly, these populations were restored without provincial or federal endangered species legislation. Rather, they were restored because they are valuable to anglers, hunters, trappers, and other naturalists who have a vested interest in protected habitats and a healthy environment.
Our legacy of game and non-game species recovery continues today with OFAH members volunteering their time and their money to the restoration of, for example, eastern elk, Atlantic salmon to Lake Ontario and its tributaries, native trumpeter swans, spotted turtles, and peregrine falcons, to name but a few.
Our efforts continue to focus on preventing species from becoming endangered in the first place. To us, it has always been clear: maintaining healthy habitats and biodiversity requires federal and provincial vigilance and support on many fronts, including protection of natural habitats through sustainable development and wise land use planning; protection of Canadian ecosystems from pollution and the invasion of harmful exotic species; provincial and federal support for private land stewardship; scientifically based fish, game, and fur-bearer population management and associated sustainable resource use; and, as the last line of ecosystem defence, effective species at risk legislation and recovery programs.
The Species at Risk Act, SARA, and associated programming should be just that, the last line of biodiversity defence. It should not, in fact must not, come at the expense of effective conservation and management programs that prevent fish, wildlife, and their habitats from becoming at risk in the first place.
That was the overarching message and concern the Ontario Federation of Anglers and Hunters expressed about Bill C-5, the Species at Risk Act, back in 2002. We warned the government of the day that Bill C-5, SARA then, would first create, through legislation, an expensive and reactive bureaucracy that would ultimately not be very effective at recovering most species at risk, and, second, would result in too many resources being directed to the service of this new species at risk bureaucracy to the detriment of existing federal fish and wildlife management and conservation programs that prevent species from becoming at risk in the first instance.
Now, eight years later, the OFAH takes no consolation in looking back and saying, “We told them so.” The SARA track record since 2002 speaks volumes, and we've documented that record for you.
Now, eight years later, we remain very concerned that other fish and wildlife management, conservation, enforcement, and habitat protection programs have suffered because of the increasing fiscal and human resource costs of this growing SARA bureaucracy.
Three years after implementation, the federal government allocated an additional $110 million for SARA implementation. In Ontario we've experienced an 80% reduction in the number of federal fisheries officers stationed in Ontario since 2006. We're also aware that the migratory game bird assessment monitoring and management programs of the Canadian Wildlife Service of Environment Canada have been cut because of the shifting of resources to the SARA program--robbing Peter to pay Paul.
The likelihood that limited resources and staff are being taken away from practical, on-the-ground ecosystem monitoring and conservation management to serve a reactive SARA paper exercise is most alarming to us. We only need to look at the longer record of the United States Endangered Species Act and associated programming to predict how ineffective and expensive the reactive single species protection model can become. Again, I urge you to particularly visit the website that provides the documentation in the next page or so of our submission to show just how expensive and ineffectual species recovery as a result of federal legislation in the United States has been over the last 33 years.
On the home front here, in 2006, Stratos presented an independent SARA audit. At the time, when we reviewed the results of the Stratos audit, quite frankly, we agreed with many of the observations and recommendations therein, and we urge this committee to revisit that Stratos report.
In fact, it forms the basis of the nine recommendations that the Ontario Federation of Anglers and Hunters brings forward to your committee. They are resource community involvement. You've heard the first speaker this afternoon refer to the importance of integrating and incorporating aboriginal traditional knowledge. In the same way, the community knowledge that resides with those who have a vested interest in the sustainable harvest of a species and/or the stewardship of habitat affected by a proposed species must be afforded reasonable opportunities to provide input into COSEWIC's species assessments, socio-economic regulatory impact assessments, and any subsequent recovery and policy development.
Under the category of assessment and listing, we have three recommendations for you. COSEWIC assessment criteria should be reviewed and amended where it does not make it clear that where there's insufficient science to accurately assess the status of a species, species should not be assessed as endangered or threatened, but rather the data-deficient category would be the most appropriate classification.
In the face of scientific uncertainty about species, it's critically important, both for accountability and relevant socio-economic conditions, that the minister retains the authority to accept or reject the COSEWIC listing recommendations. That ministerial discretion, in our view, remains important. We would of course point out the fact that the minister has accepted 449 of 551 listing recommendations--that is some 81%--which indicates to us a respect by the minister for those COSEWIC assessments.
Geographical assessments and designations at lower than the species level should be strongly discouraged in COSEWIC assessment criteria. Unless there is strong genetic evidence of geographical sub-speciation, designation of eco-types or local populations should not be proposed or accepted. On the other hand, we do recognize the value of de-listing species at a geographical level, and we would could certainly recommend that become policy.
In terms of recovery strategies themselves, we have a couple of recommendations for you. For species that could impact resource users, the OFAH strongly recommends that recovery strategy teams include non-government representatives with expertise on the sustainable management, use, and recovery of such species and/or their habitats.
We also recommend development of policies and guidelines for recovery strategy team composition, stakeholder involvement, threat assessment, and population objective setting to help ensure more consistent development of effective recovery strategies.
We also recommend the development of appropriate criteria and an effective framework for assessing the socio-economic impact of species listing and recovery planning. Regulatory impact statements should include sound socio-economic analysis, including potential costs incurred by regulators, by those being regulated, and the conservation cost-benefit for the species at hand.
We also seek increases in efficiencies from SARA, not costs. Our second to last recommendation to you is that the OFAH recommends against feeding SARA's growing appetite for more funding and human resources. Rather, large cost savings and greater efficiency would be realized if Environment Canada were more serious about harmonizing provincial and federal species at risk efforts, which, for example, in Ontario are often redundant, inconsistent, and confusing to both agencies and the public.
Thank you very much.