RE: amend O. Reg. 832/21 to…

ERO number

019-8016

Comment ID

95896

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

RE: amend O. Reg. 832/21 to shorten the timeframe from 20 to 10 years such that any part of a stream or other watercourse that was used by Redside Dace at any time during the previous 10 years would be considered to be ‘occupied’ habitat under the regulation

Where is supporting rationale / evidence / material to suggest that this will not have an overall negative outcome for the species?

RE: Plants (e.g., Vascular Plants, Mosses, Lichens)

Mitigation: Avoid the removal of individuals where possible, avoid or limit impacts to habitat where possible.

How can this mitigation be reasonably achieved? Is it reasonable to expect that individuals clearing trails will be able to identify SAR plants, mosses and lichens in order to avoid them? This seems to be a complete absence of mitigation, rather proponents have a carte blanche scenario to impact SAR plants, mosses and lichens with no expectation of regulation for any impacts to these taxa.