The proposed amendment to…

The proposed amendment to 830/21 to remove the 30-day waiting period between the submission of a Butternut Health Expert Report and the registration of an eligible activity for the Butternut conditional exemption contradicts the stated purpose of the 30-day waiting period in the regulation, which is:
O. Reg. 830/21 Section 24 (1): “30 days must elapse after the day the butternut health expert’s report is provided to the Ministry, so as to allow the Ministry to make a request to examine the butternut trees.”
This is problematic because it prevents the ministry from doing its job. If a tree is destroyed, the viable genetic germplasm of butternut in category 2 is thus lost. We have lost much of butternut’s genetic diversity already. Retaining some of that genetic diversity, clonally or by seed, can prolong the species’ survival. Many infected butternut trees live decades after canker infects them.
You are proposing to amend 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. This proposal is not based on evidence.
What should happen is the protection and enhancement of watercourses and their watersheds so that redside dace can recover and repopulate these areas. The health of redside dace is an indicator of the general health of the water and ecosystem. We all benefit from improvements to ecosystem health, and we all are affected when they decline.
Evidence of another species of fish recently rediscovered in a tribuary of the Thames River after over 20 years bears witness to that possibility. See this link: https://thamesriver.on.ca/black-redhorse-discovered-in-fish-creek/. Redside dace is in imminent danger of extinction in Ontario, and we need to do everything possible to protect our watersheds for their and the ecosystem’s recovery.