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CSEE Letter

CSEE Letter

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Published by TheTelegram

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Published by: TheTelegram on Mar 22, 2012
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03/22/2012

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 19 March 2012
 
The Honourable Keith AshfieldMinister of Fisheries and Oceans200 Kent StreetOttawa, OntarioK1A 0E6Dear Minister Ashfield,I am writing in my capacity as President of the Canadian Society For Ecologyand Evolution (CSEE). The 1000-strong membership of the non-partisan CSEEincludes ecologists and evolutionary biologists from across Canada.The concerns expressed here are made on behalf of the CSEE. They areinformed, in part, by the responsibilities I exercised as Chair of the Committee onthe Status of Endangered Wildlife in Canada (COSEWIC; 2006-2010) and asChair of the 2012
Royal Society of Canada 
Expert Panel Report entitled
Sustaining Canada’s Marine Biodiversity: Responding to the Challenges Posed by Climate Change, Fisheries, and Aquaculture 
.The CSEE has very grave concerns regarding the Government of Canada’sproposed changes to Section 35(1) of the
Fisheries Act 
. Specifically:1. The CSEE is concerned that the proposed changes were not informed bya full and appropriate consideration of the best available science;2. The CSEE is concerned that the proposed changes will prevent Canadafrom fulfilling its national and international commitments to sustainbiodiversity; and3. The CSEE is concerned that the proposed changes will prevent Canadafrom fulfilling its legislated responsibilities under the
Species at Risk Act 
.Each of these concerns is elaborated upon briefly below.Firstly, there is no evidence to suggest that the proposed revision to the
Fisheries Act 
was based on an appropriate level of consultation with, and advice received
 
2from, DFO’s Science Sector. According to the DFO website, “science is the basisfor sound decision making. DFO Science Sector provides information on theconsequences of management and policy options, and the likelihood of achievingpolicy objectives under alternative management strategies and tactics.”DFO’s website further notes that the incorporation of science in decision makingis provided through a rigorous peer review process built on the Government ofCanada’s
Framework for Science and Technology Advice: Principles and Guidelines for the Effective Use of Science and Technology Advice in Government Decision Making 
which states:“Science advice has an important role to play by contributing togovernment decisions that serve Canada’s strategic interests andconcerns in areas such as public health and safety, food safety,environmental protection, sustainable development, innovation, andnational security.”Based on the assumption that your decision was not made in violation ofdepartmental or government policy, the proposed revisions to Section 35(1) ofthe
Fisheries Act 
must have been informed by advice received by DFO’s ScienceSector. In the interests of transparency and accountability, and in the interests ofCanadian society, we respectfully request that the science advice received in thisregard be made publicly available without delay.Secondly, the proposed changes to the
Fisheries Act 
will be considered anabrogation of Canada’s global ocean and freshwater stewardship responsibilities.The CSEE notes the conclusion by the
Royal Society of Canada’s 
Expert Panelthat “Canada has fallen well short of the progress made by most developednations in fulfilling national and international commitments to sustain marinebiodiversity” and that “many targets and obligations to conserve and tosustainably use biodiversity have not been met by Canada”.The proposed changes to the
Fisheries Act 
will severely impair Canada’s abilityto protect species and their habitat and will, thus, further reduce the likelihoodthat Canada will fulfil its national and international biodiversity commitments.Thirdly, it is well-established in the scientific literature, and articulated inCanadian government policy and statute, that the protection of species habitatconstitutes the most effective means of ensuring that species do not becomeextinct. The
Species at Risk Act 
(SARA), for example, acknowledges that “thehabitat of species at risk is key to their conservation”.The proposed elimination of existing habitat protection provisions in the
Fisheries Act 
will severely impair Canada’s ability to fulfil its legislated obligations underSARA to prevent the extinction of aquatic wildlife species.

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