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In brief, the current AOC prescription for Blanding’s Turtle provides a conservative rule set for protecting BT habitat from forestry operations (Stand and Site Guide Table 4.3e - Note that although there is a General Habitat Description, it has not been used). This conservative approach is consistent with the precautionary intent of ESA habitat protection but it does not follow through. The intent of the ESA is for science to be conducted to provide an adaptive approach and provide effective and less social and economic impact. This failure of implementation has caused and is still causing significant economic impact. Ultimately this will also impair the recovery of this species through loss of respect for the ESA and government policy.
In the perfect administrative world of protection measures for a species at risk, a listed species receives immediate general habitat protection creating a precautionary level of protection around the habitat of a species. Forest managers provide workable block maps to operators. This is followed by careful research that is promptly commissioned and efficiently conducted, delivering recommendations for effective control measures that cause minimal social and economic impact. MNRF staff put in place an effective consultation process with concerned members of the public. Regulators change the appropriate guide and regulations to replace the general habitat regulation with a recovery plan that allows for reasonable operational control. Legislators ensure that the legal framework is smooth with few hurdles for managers, scientists, and operators to overcome.
At this time no part of this dream scenario is happening for Blanding’s Turtle protection.
Here are some findings:
The science that was required to deliver “recommendations for effective control measures that cause least social and economic impact” now exists.
A revision to Stand and Site Guide Table 4.3e should be achievable in a short time frame.
Based on interviews about science with all sides, changes to the BT AOC prescription would be acceptable at this time.
Complexity between all levels has led to a lack of prompt administrative response.
Moving an amendment to the BT prescription forward will be challenging given the redistribution of responsibility in a transformed MNRF.
The important concept of adaptive management, once the hallmark of sustainable management of a complex system, must be reinvigorated.
Ironically, the inherent resistance to change in regulation by a large administrative body can be beneficial to business by preventing turbulent change. In the case of BT it has caused undue delay, apparent loss of jobs and harm to business.