Ontario Federation of Agriculture Commentary
By Larry Davis, OFA Director
The Endangered Species Act, 2007 was designed to identify species at risk, protect their habitats and promote stewardship practices that will help protect these plant and animal species. Ontario agriculture is no stranger to this legislation as many habitats of endangered, threatened, or species of special concern are found on or around farmland.
The Ontario Federation of Agriculture (OFA) was active in consultations when the original legislation was passed in 2007. And as part of the 10-year review of the Endangered Species Act, we have submitted a detailed response with our recommendations for amendments to the Act.
From our perspective, the fact that many of the species on the risk list have habitats on and around farms shows the suitability of agricultural land as a favourable habitat for species that are endangered, threatened or of special concern. For some outside our industry, the habitat locale seems to argue for habitat protection at all cost – even over food production. That’s just not a sustainable solution.
There are three areas of OFA’s submission that warrant highlighting – a landscape approach, species recovery policies and the concept of safe harbour.
OFA agrees that the government’s proposed landscape approach that could streamline recovery strategies by protecting broader habitat types. This approach could see the protection of one species benefit from habitat protection of another species that requires a similar habitat. We encourage the government to work more holistically with this landscape approach and consider the critical interaction between species when it comes to habitat protection.
The current Endangered Species Act includes very ambitious timelines for how the province develops a recovery strategy when a species is identified as endangered or threatened. Given the number of species on the Species at Risk in Ontario list, OFA recommends the government review the timelines set out for species recovery activities, including a comparison with what other provinces do as well as the federal Species at Risk Act.
OFA welcomed the addition of the safe harbour agreement to the Act in 2018, but this component of the legislation needs to go one step further to be effective. When habitat is created or enhanced on a farm, the impact may extend to neighbouring properties. But under the current legislation, the safe harbour agreement only covers the farm where habitat is developed. That means neighbouring farms are exposed to the full weight of the legislation if the protected habitat expands onto their lands. Nature doesn’t abide by property lines, and OFA wants safe harbour provisions to automatically apply to neighbouring farms. OFA also strongly believes that species at risk that are known predators of livestock and crops must not be eligible for habitat creation under the safe harbour agreement.
Ontario agriculture provides a range of environmental and ecological goods and services for the benefit of the entire province, including habitat protection. We understand the delicate balance that nature sometimes requires, and we take our role and responsibility as environmental stewards very seriously. To read our full submission on the 10-year review of the Endangered Species Act, 2007, visit the resources page of the OFA website and click on “Submissions and Correspondence.”