Canadian Ecosystems Alliance submissions


March 17, 2016



Fisheries and Oceans Canada (Gulf Region) 

Species at Risk Program
343 Université Ave 
Moncton, NB  E1C 9B6


Re: Public consultation on federal listing of the American Eel under the Species at Risk Act


In 2012, the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) documented the serious decline in the American Eel population across much of its Canadian range mainly as a result of human activities, and as a result designated the species as Threatened (COSEWIC, 2012). The scientific evidence in support of this designation is indisputable. Therefore, the American Eel must be added to the federal list of Species at Risk.


Federal listing of the American Eel is critical so that a national Recovery Strategy for the species can be drafted and implemented as soon as possible. The current patchwork of strategies at the provincial and regional level has not proven effective as the American Eel population has continued to decline and, indeed, the species has been extirpated or is facing extirpation from large portions of its historical range. A much more integrated approach, with federal leadership, is urgently needed to address the numerous threats from fishing, dams, hydro turbines, habitat degradation and pollution.




Despite an American Eel fishing ban in Ontario and a variety of fishing restrictions in other provinces, fishing remains an important threat to the survival of the American Eel, especially in the St. Lawrence River watershed and Gulf of St. Lawrence. In the upper portion of the watershed in Ontario, the American Eel has been “completely extirpated from extensive areas” and is in “steep decline in the remainder of the province’s waterbodies” (MacGregor et al. 2013, p. iv). Loss of this population is of particular concern because Ontario’s eels are virtually all females and are among the largest eels (MacGregor et al. 2013, p. 4-5). In returning to the sea to reproduce, they carry several times the number of eggs compared to smaller eels originating elsewhere (depending on size, the number of eggs can vary from 3.4 million to 22 million; COSEWIC 2012, p. 29-30). As a result, Ontario’s eels are considered to be “an important segment of the global population” (MacGregor et al. 2013, p. iv). The current fishing ban in Ontario is of only limited use in addressing the decline in the Ontario eel population, because they must still run the gauntlet of the fisheries in Quebec and the Maritimes to reach the sea. Federal listing of the American Eel will provide a tool with which to facilitate the removal of fishing pressure on the species in the St. Lawrence River watershed and Gulf of St. Lawrence.


Dams and hydro turbines:


A national recovery strategy is needed to address the major threats from dams and hydro turbines. There are many thousands of dams in the St. Lawrence River watershed which block the upstream passage of the American Eel and other species (COSEWIC 2012, p. 64). Only a tiny fraction have fish passageways or passageways designed specifically for eels. Even dams currently under construction are usually not being equipped with passageways. The lack of passageways is of particular concern for species that migrate over long distance, such as the American Eel.


Downstream passage is of equal concern because of the high rate of mortality in hydro turbines (COSEWIC 2012, p. 66). The largest eels, such as those from Ontario, suffer the highest mortality in turbines (COSEWIC 2012, p. 66), which adds to the threat from fishing described above. In many instances eels migrating to the sea must pass through a number of hydro facilities resulting in even more devastating cumulative impacts.


Habitat degradation and pollution:


Most American Eel habitat is within highly populated and industrialized regions of the country. Land use practices associated with urban and industrial development (e.g., logging, agriculture) have an important effect on eel habitat, water quality and the level of biological and chemical contaminants (e.g., COSEWIC 2012, p. 67, 70-73). Winter drawdown in hydro reservoirs can damage habitat (COSEWIC 2012, p. 68). These various stresses are growing rapidly as the human population and its associated infrastructure and pollution continue to increase. Only a national recovery strategy can effectively deal with these complex issues.


Duty to act:

It is morally wrong to drive a species to extinction. In the case of the American Eel, the science is clear; the Eel is in grave danger through much of it range because of human activities. Therefore, Canadians and their government have a duty to act to stop the decline in the American Eel population and assist the species to recover. The Cod debacle of the 1980’s must not be repeated.


It is critical that the federal government accept the scientific assessment of COSEWIC, list the American Eel under the Species at Risk Act and prepare and implement a comprehensive Recovery Strategy.


COSEWIC. 2012. COSEWIC assessment and status report on the American Eel Anguilla rostrata in Canada. Committee on the Status of Endangered Wildlife in Canada.

MacGregor, R., J. Casselman, L. Greig, J. Dettmers, W. A. Allen, L. McDermott, and T. Haxton. 2013. Recovery Strategy for the American Eel (Anguilla rostrata) in Ontario. Ontario Recovery Strategy Series. Prepared for Ontario Ministry of Natural Resources.


October 29, 2015

Rebecca Zeran

Program Advisor

Ministry of Natural Resources and Forestry

Policy Division

Natural Resources Conservation Policy Branch

Natural Heritage Section 8M5

300 Water St.

Peterborough, Ontario K9J 8M5

FAX 705-755-1971

Dear Ms. Zeran:

Re: EBR Registry # 012-4464, Wetland Conservation in Ontario: a Discussion Paper

The Canadian Ecosystems Alliance supports the protection and restoration of fully-functioning ecosystems. We view the Earth from an ecocentric perspective. Healthy ecosystems are vital to the overall health of the planet and to our own well-being. Healthy ecosystems must take precedence over developers’ profits.

Ontario wetlands are of particular concern because of the huge losses that have occurred and the ongoing grave threats to these ecosystems. Therefore, we wish to take this opportunity to make the following comments on the state of wetlands in Ontario and the Discussion Paper on wetland conservation in the province.

Current status

Wetlands are among the most diverse ecosystems in the province. Unfortunately they are also among the most damaged and threatened ecosystems, especially in the south. In some areas most wetlands have been lost (Discussion Paper, p. 8) as a result of agricultural and other forms of industrial development, urban expansion and flooding by hydro and other types of dams. Many others have been fragmented by roads or severely degraded as the result of nearby development and pollution. Wetlands in the rest of the province are facing increasing threats as development increases in the north (Energy East tar sands pipeline proposal, Ring of Fire mining proposal, hydro-electric development, new roads, etc.). Climate change is also likely to have negative effect on wetlands in the province.

Currently, there are a number of individual pieces of legislation (and regulations) that address wetland conservation in Ontario (Discussion Paper, p. 10). Unfortunately, they have failed to stem the ongoing loss of and damage to wetlands in many parts of the province. A comprehensive Strategic Plan for wetlands in the province is urgently needed.

A Strategic Plan for Ontario Wetlands

We support the proposal in the Discussion Paper to develop a Strategic Plan for Ontario wetlands and make the following recommendations on some of the important issues that the Strategic Plan should address.


1. The Strategy must have primary focus on protecting existing wetlands, and restoring those that have been degraded. It must start from the premise that all wetlands are important, no matter their size, and deserving of protection.

2. The Strategy must ensure that there is a substantial “net gain” in wetland area and improved functionality. We do not support the proposal in the Discussion paper (e.g. p. 22-23) for a “no net loss” policy. This is essentially the status-quo, and it isn’t working as wetlands continue to disappear or deteriorate. Studies have demonstrated that replacement wetlands are usually not of the same quality as existing wetlands which have developed over thousands of years. Also see point #4.

3. The Strategy must ensure that the vast majority of wetlands in the province are fully protected from all development (including Provincially Significant wetlands, coastal wetlands along the Great Lakes, wetlands in southern areas in which a large percentage have already been lost, wetlands of the Hudson Bay Lowlands which include vast peatlands, wetlands with Species at Risk, all wetlands that have not yet been evaluated –see point #8). Protection should be immediate and permanent. Only in very unusual circumstances should development be permitted in or adjacent to the remaining wetlands that are not fully protected.

4. In order to act as a significant disincentive to developers and other seeking to destroy or damage any wetlands that are not fully protected, we recommend that there be a high ratio (10:1) for replacement wetlands. Such a policy will make it much less likely that wetlands will be targeted for development.

5. In the very unusual circumstances where a wetland is damaged or destroyed, any replacement wetland (10:1 ratio) should be located in the same local area.

6. The Strategy should address the various threats to wetlands: fragmentation (especially due to roads), invasive species, climate change, industrial development, sources of pollution, etc. With respect to fragmentation of wetlands, the strategy should prohibit new roads in wetlands. The only exceptions should be roads that are designed to avoid fragmentation (e.g. elevated roadways such as the 30 km section of Interstate 10 across the Atchafalaya wetland or the 3 km section of Interstate 310 across the LaBranche wetland, both in Louisiana). Existing roads in wetlands should be assessed and upgraded as quickly as possible with the assistance of experts in road ecology to reduce fragmentation and ensure wildlife passages are provided. Where this is not possible, they should be rerouted around the wetland.

7. The Strategy should address the currently inadequate Environmental Assessment process. The process must ensure that development projects do not harm wetlands, rather than acting merely as a rubber stamp for projects.

8. We support a review of the Ontario Wetland Evaluation System (Discussion paper, p. 20). In addition, the Strategy should establish a process and timeline to complete the evaluation of all wetlands in the south, as well as those in northern regions where development is proposed or expected. Currently many wetlands even in the south have not been evaluated (Discussion Paper, p. 11).

9. The Strategy must establish a process for effective collaboration to protect wetlands between provincial government departments and environmental and conservation organizations, municipalities, landowners, etc.

10. It is also critical that there be adequate funding to carry out a wetland protection mandate as well as for monitoring and for enforcement of regulations.