Trout Unlimited Canada (TUC)…

Trout Unlimited Canada (TUC) is an environmental charity focusing on restoration and conservation of aquatic ecosystems throughout Canada. In collaboration with our local chapters and other partners, we have a history of working in current and historical Redside Dace habitat to improve water quality, reduce water temperatures, and to rehabilitate fish habitat. This has included sections in the Bronte Creek watershed, the Credit River watershed, and most recently, in Irvine Creek where TUC has been actively working to restore habitat for Redside Dace through tree and shrub plantings and the identification of sites in need of erosion control, channel narrowing, and other restoration works.

Trout Unlimited Canada disagrees with the proposed amendments to O. Reg. 832/21 as it pertains to the Redside Dace and its habitat, especially considering how the shortening of the timeframe for a stream to be considered “occupied” from 20 years to 10 years will remove protections on several waterbodies, including Irvine Creek. We believe this is an inadequate and seemingly arbitrary method to delist vital habitats and suggest the process should instead incorporate a more robust and sampling-based methodology for deciding when a stream reach is no longer occupied; for example, repeated sampling, using a variety of techniques, over successive years. In this example, the habitat is no longer considered occupied after no detections after a set number of years. A similar program has already been utilized with other species at risk, such as the Jefferson Salamander, which requires five years of sampling, with five surveys per year, before presence can be ruled out. We believe a similar sampling protocol would be a more appropriate method for considering Redside Dace habitat to be no longer occupied.

Furthermore, we believe that environmental DNA (eDNA) should play a role in determining the occupancy of Redside Dace, as it has already been used to identify stream reaches the fish may be and to direct further sampling. While we recognize there is still uncertainty surrounding the efficacy of eDNA sampling, this could be mitigated through repeat sampling over successive years. This would be especially useful for a species such as the Redside Dace which is notably elusive and prefers to live beneath dense shrubs, making traditional survey methods like seine netting less effective and more prone to incorrectly returning an absent result.

TUC is also concerned with the proposed change to the definition of recovery habitat. The proposed amendment limits Redside Dace recovery to natural recolonization from existing populations into adjacent areas, and prevents all possibility of reestablishing populations in other suitable habitat within their native range.

Ultimately, these changes would result in the Redside Dace being unable to grow beyond the need for government intervention. Strong legislation and collaboration is required to enable not just maintenance of populations but the recovery of endangered species.

Thank you for the opportunity to provide feedback on the management of endangered species in Ontario. We look forward to working cooperatively with the MECP to protect and restore the province’s ecosystems and species at risk.