- What are the factors…

- What are the factors driving the need for this change?

- Given that there are many watersheds that will be impacted by the proposed changes, how will
MECP staff be directed to deal with records that are older than 10 years in terms of occupancy?

- For reaches where occupancy is considered older than 10 years, how will MECP update
occupancy across the species range considering the following:

× Limited monitoring occurs specifically for species at risk, including Redside Dace, due to
limited resources as well as recent changes to the Conservation Authorities Act.
Conservation Authorities are now restricted to Category 1 services (unless identified
under an MOU with regional and municipal entities), thereby limiting the amount of
watershed-based or targeted sampling for species at risk and therefore their ability to
conduct regular local monitoring, resulting in outdated records and observations for
occupied and recovery habitat.

x When the resources are available to sample Redside Dace, targeted sampling is no
longer an activity that can be registered under the provincial Endangered Species Act,
2007. Instead, a 17(2)(b) permit is required with minister approval. Acquiring this permit
may result in significant delays thereby impacting sampling efficiency and project
timelines. Additionally, we know that, in 2023, some of these permit applications for
Redside Dace monitoring were denied with no reason given. How will MECP address the
increased need for these permits plus the short timelines required for their issuance?

x What level of sampling will be required to confirm occupancy? Successful sampling for
this species depends heavily on methodology, seasonality, and gear types. In addition,
multiple sampling events over years may be required to confirm occupancy due to the
rarity of this species.

x The established 20-year occupancy limit was based on a North American standard
established by NatureServe. Science based protocols/definitions should be used and should incorporate species specific sampling over an extended period before occupancy
can be confirmed (e.g., occupancy definition for Jefferson Salamander). How was the
new 10-year occupancy limit determined?

x Will eDNA now be accepted as a means of confirming occupancy? How will the use of
eDNA be incorporated to confirm the presence of the species in occupied/recovery
habitat? As with physical sampling, a specific protocol with repeatable eDNA collection
should be required to confidently confirm occupancy.

- For recovery habitat, what criteria will be used to determine whether a stream or watercourse is
“directly adjacent” to occupied habitat? How will restoration opportunities, overall benefit projects,
barrier removals, etc., influence/impact these criteria?

- For recovery habitat, what scientific criteria will be used to determine whether a reach is “currently suitable” to carry out the species life processes? What scientific monitoring or assessments will be
used to determine this and who will conduct this work?

- How does the change to the act uphold and protect First Nations treaties and rights?

- Redside Dace reaches and watersheds currently mapped as occupied or recovery habitat are
consistent with mapping of Critical Habitat in the federal Recovery Strategy and Action Plan. Given
the protections afforded to the species under the federal Species at Risk Act, how will MECP address inconsistencies in occupied and recovery habitat due to differences in the identification of these habitats between the two acts?

- Is there any consideration for using keystone species for Redside Dace (e.g. Creek Chub or other Nocomis species) as part of habitat, and not just the physical habitat (geomorphic units) of a stream or directly adjacent riparian areas?

- If this is meant to ‘focus’ on best ensuring persistence of Redside Dace populations/habitats, will there be assessments to determine which locations are critical, and concurrent amendments to have Redside Dace strongholds legally established (i.e., surrounding land protected from development)?