by the OFNC’s Conservation Committee
The Blanding’s Turtle needs your help. Kanata Lakes North Development Inc. in Ottawa is proposing to “Kill, harm and harass Least Bittern as well as damage up to 10.9 hectares of Least Bittern habitat” and “Kill, harm and harass Blanding’s Turtle as well as destroy up to 124 hectares of Blanding’s Turtle habitat.”
To do that they have applied to the Ontario Ministry of Natural Resources and Forestry (MNRF) to get an “overall benefit” permit under the Endangered Species Act (ESA). If you think destroying up to 124 ha of habitat is NOT an overall benefit to these species, please submit a comment via the Environmental Bill of Rights (EBR). The more people who calmly and rationally object to this proposal, the more likely it is that MNR will reject or modify the proposal.
In theory, to get an overall benefit permit, KNL must do more than simply recreate what is lost. The proposal calls for creating nesting and overwintering habitat for Blandings Turtles. Potential nesting habitat, open areas where turtles can lay their eggs, can likely be created, although whether the turtles will use it is not known. And whether it will be persist for decades is another question. (Note: Blandings Turtles can live to be 80 years old; they don’t begin to reproduce until they are 14-20.)
Creating overwintering sites is more complicated. If conditions are not right in the created wetland, it could freeze to the bottom killing any turtles that were forced to hibernate there.
You can help
Please read the following letters written by knowledgeable and respected members of the OFNC’s Conservation Committee. Feel free to use any of their content to make your case.
It is always best to personalize an EBR submission so that it does not look like a form letter. You can do that by writing a different opening sentence or two, adding a personal comment about habitat loss, rewriting a few sentences in your own words, or cutting a few sentences as well. Remember any comment against this is better than none, so don’t agonize over drafting the perfect letter.
- Submit your comments on the EBR form. Click the “Submit Comment” button in the right column here – http://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTI3MTcw&statusId=MTkyMDg1&language=en. Once you’ve filled in the form and your comments, click “Save” to add them to the ministry’s database file.
- It helps to also send a copy of your comments to Premier Wynne (firstname.lastname@example.org).
The deadline for comments has been extended to 17 February 2016. Please be sure to add your voice to this effort to save our threatened Blanding’s Turtles.
Sample letter prepared by David Seburn
Destroying up to 124 ha of Blanding’s Turtle habitat is not an overall benefit to this threatened species. The permit requested by KNL for this development cannot be granted. KNL must demonstrate a net benefit to the species. As the EBR posting states, an overall benefit “is more than ‘no net loss’ or an exchange of ‘like for like’”.
The proposed development states that it will “destroy up to 124 hectares of Blanding’s Turtle habitat.” If this enormous loss of habitat contains any wetlands that are known overwintering sites for the Blanding’s Turtle then the proposal must be rejected. Creating nesting habitat for turtles is potentially straightforward if done carefully. Creating appropriate wintering habitat is quite another. If turtles select an overwintering wetland with the wrong conditions they will die. If KNL is permitted to destroy overwintering wetlands and create other ponds for the turtles to hibernate in then this would be an experiment. It would not be a net overall benefit to the species.
To truly provide an overall benefit to the species, then if >100 ha of habitat is to be destroyed, >200 ha of additional primary habitat must be created. And that habitat should not consist of backyards and storm water ponds, but woodland habitat and complex wetlands, forming a network of connected habitats for this population.
Wetland loss is a serious issue in this province. It is difficult to imagine how anything resembling an overall benefit can come from destroying >100 ha of habitat. All the Blanding’s Turtles in that area must be relocated and somehow kept from returning. If even a few adult females are left behind and die during the process then this is not an overall benefit as the demographic structure of turtle populations requires extremely high rates of adult survivorship. Those turtles that are relocated may be moved to areas outside their normal home range. They will likely be disoriented and attempt to return to their previous home range as many translocation studies have demonstrated. Turtles making such long distance movements are likely to have to cross many roads and face a high probability of being killed on roads.
Blanding’s Turtles can live for more than 50 years. Any actions taken to benefit the species must be maintained for 50 years at a minimum. This includes nesting habitats, fencing and created wetlands. Creating a nesting habitat that is only maintained for 20 years is not an overall benefit to a species that can live for so long.
In conclusion, causing the death of Blanding’s Turtles and destroying >100 ha of their habitat is not an overall benefit to this species and this permit should not be granted.
Letter submitted by Fred Schueler
The proponent’s proposals to “minimize adverse effects on individual members of each species” and “achieve an overall benefit for each species” are both corrupted by the words “may include.” In a situation where a keystone area of habitat would be removed, there must be concrete detailed plans, based on local research into the populations to be affected, before “net benefit” can even be speculated about.
With Butternut and Least Bitterns the habitat requirements are fairly well understood, and a prospective plan (which is not presented here) could conceivably be evaluated. For a species as cryptic and wide-ranging as Blanding’s Turtles, where the wintering habitat is so different among different populations, and a process such as wetland construction for mitigation of destroyed habitat, where the failure rate is so high, the only acceptable way to allow a plea of “net benefit” would be to first
- support a research project to track and monitor the movement of the turtles to see if there is a deficiency of nesting and overwintering habitat near the to-be-destroyed habitat, then
- create the new nesting and overwintering habitat, and then
- support a research project to track and monitor the movement of the Turtles to see if the new habitat features are used enough for the post-destruction population to be larger than that which is present now. This would take at least a decade, and perhaps by then the proponent’s financial backers would have lost interest or become impatient.
- allow the habitat to persist. The more merciful thing – for the Turtles, the proponent, and the ecosystem – is to treat the proposed “net benefit” scheme as the fantasy it has so clearly been composed as.
on this issue can be found on the Greenspace Alliance’s web site
Or contact David Seburn at davidseburn at sympatico dot ca.