• Protecting Water and Farmland in Simcoe County

Recovery Strategy for the Hine’s Emerald (Somatochlora hineana) in Canada

In Adjala-Tosorontio
Oct 1st, 2019
Hine's Emerald Dragonfly -Chris Evans photo

Hine’s Emerald Dragonfly, found for the first time in Canada, in the Minesing Wetlands in 2007.

The following is Chris Evans’ submission to the ECCC Recovery Strategy Team, September 30, 2019:

Thank you for the opportunity to comment on this important proposed Federal Recovery Strategy for the Hine’s Emerald (Somatochlora hineana) in Canada (FRS)1.

I am the amateur naturalist who first captured, and misidentified, the Hine’s Emerald in Canada at the edge of the Minesing Wetlands on June 20th, 2007. I contacted Colin D. Jones at the Ontario Ministry of Natural Resources- Natural Heritage Information Centre (NHIC) who then correctly identified the species as Hine’s Emerald. With Colin’s encouragement and guidance I then led a team, including Colin, to gather evidence to enable the preparation of the Draft COSEWIC2 Status Report for Hine’s Emerald (COSEWIC 2011)2. Colin then prepared the COSEWIC 2011 report which ultimately led to the Federal listing of the species as Endangered under the Canada Species at Risk Act (SARA 2002)3 in May 2011. This was then followed by the Ontario Provincial listing for Hine’s Emerald as Endangered under the Ontario Endangered Species Act (ESA 2007) in 2012. I was part of a team led by Tanya Pulfer, formed in 2012, which developed the Ontario Recovery Strategy 2013 (ORS 2013)4, now adopted by Environment and Climate Change Canada and contained in the proposed FRS1. I was part of another team led by Tanya Pulfer, formed in 2014 which prepared the report “Hine’s Emerald (Somatochlora hineana) Dragonfly Study in Minesing Wetlands:
An investigation into the habitat, species, associated species and threats.”5

Comments on the FRS
Upon reading the FRS and the Species at Risk policy on survival and recovery 2016 (SAR Policy 2016)6, I submit that the FRS’s assessment of Hine’s Emerald as “historically precarious” is unsubstantiated and, thus, the FRS as proposed does not appear to satisfy the SAR Policy 2016 “2.0 Policy Objective” or “5.0. Standards to be Followed”.

Further, I agree with the “No.” conclusion of the FRS Appendix A, Historical Context criterion 4. However, for completeness and consistency, I will apply my arguments refuting the conclusions for Appendix A, Historical Context criterion 3., to the FRS rationale given for criterion 4. to refute the rationale while supporting the conclusion.

I will also argue to extend the Critical Habitat of Hine’s Emerald:
to a modest degree considering recent evidence of which the FRS may not have been aware and,
to a large degree considering the threats of climate change and human activities on recovery of this species

Arguments in refute of Historical Context – Criterion 3. Yes.
While I have insufficient time and resources to “collect [all] the best available information on:
The historical condition of the species”6, I have done my utmost to gather some of the best
historical information on the human impacts to wetlands and forests in southern Ontario, Hine’s Emerald critical habitat components1, ecology science and connected natural heritage systems, to support my assertion that Hine’s Emerald most likely existed at many more than five locations “prior to significant effects of human activity”1. I intend to use this information to show that Hine’s Emerald was most likely not historically precarious.

Please consider the following arguments in support of my submission. The Appendix below contains additional details in support of these arguments.

In the excerpt below from the Historical Context section of the FRS, I have made bold the conditions on satisfying the “historically precarious” criteria, specifically criterion 3., which I submit contains an unsubstantiated belief which has erroneously resulted in the FRS’s assessment of Hine’s Emerald as “historically precarious”.

498 Historical Context
499 The first step in determining the recovery feasibility of the Hine’s Emerald is to establish
500 the historical context (whether the species’ existence in Canada was historically
501 precarious or not precarious). To make this determination, Environment and Climate
502 Change Canada uses the four criteria outlined below. A species is considered to have
503 been historically precarious if any of the following are known or likely to have been true in
504 Canada, prior to significant effects from human activity:

517 3. The species existed at five or fewer locations24 or less than 20 km2 index of area of
518 occupancy25 (IAO);
519 • Yes. The Hine’s Emerald is known from only one location in Canada despite
520 survey efforts at other potentially suitable locations. Although there has been
521 extensive wetland loss in southern Ontario, the species is not believed to have
522 historically existed at more than five locations. The species has an index of
523 area of occupancy (IAO)26 of 28 km2 (COSEWIC 2011) however, it has only
524 ever been reported at one location in Canada.

Lines 503 and 504 above allow a criterium to be satisfied if it is either known or likely to have been true.

Note that there is no citation for the above belief that the species did not historically exist at more than five locations, which I will hereafter refer to as the belief. It is preceded by three scientific facts, none of which substantiate the belief, and the third of which actually casts doubt upon the belief.

The two facts that “The Hine’s Emerald is known from only one location in Canada” and “despite survey efforts at other potentially suitable locations” appear to prejudice the FRS towards thinking these facts suggest it was historically precarious. i.e. it appears the invalid logic here is:
if it is critically endangered now, it is likely to have been historically precarious
There is no evidence to support this invalid logic. While perhaps some critically endangered species were historically precarious, not all were historically precarious.

I will establish by the following historical facts, that the most likely reason Hine’s Emerald is critically imperilled in Ontario today is that human activities in Southern Ontario have destroyed or made unsuitable, nearly all of the historical habitats of Hine’s Emerald.

Contrary to the belief stated in the FRS, if the bulleted facts cited in the Appendix below are considered scientifically and objectively, they lead to the conclusion that Hine’s Emerald most likely existed at more than five locations historically in Ontario. The FRS cites that the known habitat requirements are very restrictive and uses the unsubstantiated belief to suggest that the present day known occurrences of that habitat are likely fewer than 6. Yet, the primary threat to Hine’s Emerald is human development activities (USFWS RP 2001)7, which began in earnest in southern Ontario in 1800.(Riley 2013)8 So by the time Hine’s Emerald was first described to science By Williamson in 19312, a significant portion of the wetlands in southern Ontario had been completely lost due to the direct or indirect negative impacts of human activities.9

Please consider that the fur trade impacts, particularly upon nature’s wetland engineer, the beaver, could be researched historically to ascertain these human induced impacts on wetlands prior to the 1800’s. It might be discovered that significant negative impacts to wetlands and forest ecosystems due to decline in beaver populations occurred prior to 1800. (John Riley, The Once and Future Great Lakes Country – Taking the Wildlife 1500 to 1900)8

So beaver and wetlands may or may not have suffered significant changes prior to 1800 due to the fur trade, but they certainly suffered dramatic changes before 1900 in that the deforestation of southern Ontario was in the range of 80 to 90%.(John Riley, The Once and Future Great Lakes Country – Taking the Wood 1500 to 1900)8

Wolves and wild game were abundant in Simcoe County in the early 1800s.10 Considering trophic cascade ecology11 implications, I conclude southern Ontario hydrology and wetland functions underwent dramatic changes as wolves and other top predators were extirpated from southern Ontario, thus, magnifying the direct negative effects of human activities on the ecology. But trophic cascade also suggests ecological recovery can be equally dramatic by the restoration of the natural balance of the predator prey ecology.12

Thus, before the Hine’s Emerald was even described by science in 1931, at least 80 to 90% of the Hine’s Emerald functional habitats in Canada were destroyed, and the functionality of all of its remaining possible habitats in southern Ontario were negatively impacted by human activities, either directly or indirectly. By the time of its discovery in Minesing Wetlands in 2007, while a few of those historical habitats have been recovering and others have been further impacted by intensifying urbanization (pers. comment Dave Featherstone NVCA), and whereas a few other sites may still harbour Hine’s Emerald1, only one known location exists.

During this same period of time of intensive and extensive human activity, the passenger pigeon, numbering in the billions in the early to mid 1800s, became extinct by 1914 due to overhunting and habitat (forest) destruction.13 This vertebrate’s existence and fate was documented because it was known for its value as food and because its physical presence was obvious. Its documented anthropogenic fate suggests the undocumented historical Hine’s Emerald populations may well have been ample and stable, too, but the anthropogenic loss of habitat has brought it to the brink of extinction in Canada and the US.

Another dragonfly of the same Genus as Hine’s Emerald, the Plains Emerald (Somatochlora ensigera) is now found in the Rainy River district of Ontario and “is known in southern Ontario from a single record near Stroud in 1959” (Somatochlora of Southern Ontario, Peter B. Mills 2015). Plains Emerald has a Conservation Status Rank in Ontario of S1, “critically imperilled” like the Hine’s Emerald. Modern day dragonflies have developed from ancestors originating at least 300 million years ago. “Since then, other insect groups have diverged and evolved, developing different body structures and lifestyles and creating entirely new orders”. “In spite of all the new development in the insect world, current day Odonata [dragonflies and damselflies] have changed relatively little in body design from those in the fossil record – a testament to what is obviously a successful design.” (Colin D. Jones et al 2013)14 Considering these facts, is it not much more likely that both Hine’s Emerald and Plains Emerald were both secure residents of southern Ontario (likely S5 Rank?) considering “Southern Ontario has lost over 72% of its wetlands [from 1800 to 2002 due to human activities], and wetland loss continues today. ”9? This 72% figure does not even consider the damaging impacts to the remaining wetlands and natural heritage systems due to human activities prior to 1800 through to the present, which rendered these remaining wetlands unsuitable for these two species, most likely taking them from S5 status ranks to S1 over a period of about 200 years.

To estimate the number of lost habitats, we simply divide the number of known existing Hine’s Emerald habitats of 1 (assuming no other populations exist), by a very conservative estimate of 20% (100% – 80% lost = 20% remaining) remaining habitats (assuming that only 80% of Hine’s Emerald habitat has been lost, though clearly this figure is very conservative), we arrive at a minimum of 5 lost populations due to habitat loss. By this simple argument, historically Hine’s Emerald existed in Ontario in at least 6 populations, which refutes the belief and results in criterion 3. response as “No.”, so Hine’s Emerald was not historically precarious in Canada.

Forming a more refined and slightly more complicated argument, I will now use the species’ maximum limited dispersal of 5.4 km for adults (COSEWIC 2011) to again conservatively argue that the historical population was likely much greater than six. To illustrate my logic, I ask the question “How did the Hine’s Emerald come to exist in Minesing Wetlands?”. To answer this we need to go relatively far back in time. From Wikipedia, the most recent glaciation event to cover southern Ontario and the midnorthern US was the Wisconsin glaciation from approximately 75,000 to 11,000 years ago. Sometime after 11,000 years ago, the landscape slowly recovered from glaciation, geography shifted and species dispersed northward through the midnorthern US to Ontario and beyond creating the associated wetland, meadow and forest habitats Hine’s Emerald requires. Science suggests that this dispersal happened for Hine’s Emerald about 4,000 years ago4. So, using this maximum dispersal of 5.4 km for Hine’s Emerald and modern geography as an approximation, we can calculate the minimum number of Hine’s Emerald populations required to result in dispersal of Hine’s Emerald to Minesing Wetlands via the US. The nearest extant Hine’s Emerald population to Minesing over land is in Mackinac County, Michigan. The distance from Mackinac County over land in Canada to Minesing Wetlands is 350 km, not considering where wetlands might be along that route and recognizing that in current geography that requires a 30 km flight from Manitoulin Island over water to Tobermory. However, this is an approximation looking for a likely minimum, and that flight may have been across wetlands when this dispersal took place, or the dispersal may have taken a different route. The calculation: 350 km / 5.4 km between populations = 65 as an approximate minimum number of populations of Hine’s Emerald along a curving line between the US and Minesing Wetlands sometime over the last 4,000 years or so. If one considers that the Hine’s Emerald would not have dispersed in a straight line to Minesing Wetlands there would likely have been many multiples of 65 populations in order that Hine’s Emerald could have come to exist in Minesing Wetlands. Another consideration is that several extant populations of Hine’s Emerald in the US occur north of Minesing Wetlands, so it is possibly more likely this dispersal came from the south, so the Hine’s Emerald population in Minesing may have been established from a southern route and dispersed to more northerly locations as described in the USFWS RP 2001. This would suggest Hine’s Emerald could have historically existed throughout southern Ontario, and may still be present at a few scattered locations.

By this more complex argument, historically Hine’s Emerald existed in Ontario in at least 65 closely linked populations, which again refutes the belief, and results in a response of “No.” criterion 3., so Hine’s Emerald was very likely not historically precarious in Canada.

Because this “first step” of assessing the historical context in producing the FRS is now shown to be currently incorrect, the SAR Policy 2016 requires that the FRS be significantly revised and expanded.

Arguments in refute of Historical Context – Criterion 4. rationale
The historical context 4th criterion excerpt from the FRS below contains rationale which I perceive to be incorrect. I have made the rationale bold in the following:
“525 4. The species was dependent on connectivity with populations outside Canada for its
526 long term presence in Canada.
527 • No. There is no evidence to suggest that historic or current Hine’s Emerald
528 populations in Canada were connected to populations in the United States due
529 to the species’ limited dispersal, specific habitat needs, and vast geographic
530 separation between populations. The closest occurrence in the US is 280 km
531 away in Michigan (COSEWIC 2011).”
While the FRS concludes “No.”, with which conclusion I agree, i.e. that this criterion is not satisfied, I disagree with the statement in bold on lines 527 through 530. To paraphrase and break down this statement, my evidence and arguments regarding criterion 3. show:
the historic Hine’s Emerald populations in Canada most likely “were connected to populations in the United States due to the species’
limited dispersal” characteristics,
necessarily historical less specific wetland habitat needs compared to present needs and
necessary historically close “geographic separation between populations”,
all of the above are required in order for the species to have become so widely distributed in its present day context, through a previously glaciated landscape, and to come to exist in Canada.
i.e. Hine’s Emerald’s cited limited dispersal abilities mean that it could not have jumped from unglaciated southern habitats to Canada. It had to have dispersed across the formerly glaciated US from the non-glaciated US zone, where Hine’s emerald survived the glaciation period, and subsequently dispersed to what is now southern Ontario. The facts that:
the (USFWS RP 2001) has a clear and viable plan to recover both known historical and potentially historical connected Hine’s Emerald habitats in the US and
the US and Canadian habitats and human history are not dissimilar,
is strong evidence that these widely separated historical populations were once closely connected with many unrecorded populations and only became widely separated due to human activities, which human history shows has destroyed over 80% of Hine’s Emerald habitat in Ontario since 1800. This is compelling evidence that historic Hine’s Emerald populations in Canada were historically connected to populations in the United States. However, I have also shown that likely many historic populations of Hine’s Emerald existed in Canada. Thus, the species was not historically, and is not presently, dependent on connectivity with populations outside Canada for its long term presence in Canada.

Arguments to extend the proposed Critical Habitat of Hine’s emerald near Minesing Wetlands

While many of the essential complex habitat parameters of present day Hine’s Emerald habitat are either not known or not yet clearly understood, the known present day habitats of Hine’s Emerald do exhibit some common attributes which help identify its most likely remaining extant habitats for surveying purposes and for priority potential recovery habitats. Please note that due to the inability of science to determine or describe the historical habitat requirements of Hine’s Emerald and the number of populations which existed prior to human activity due to the lack of persistent physical evidence of insects in the environment and a complete lack of knowledge of the historical specific ecology of the species, comprehensive knowledge of the historical habitat does not exist and must be inferred from what is known now about extant populations and the few known historical populations. The precautionary principle in the SARA 2002 suggests we assume that the habitat needs of Hine’s Emerald were broader than they appear to be at present to ensure we protect sufficient viable habitats for recovery of the species. As I have shown, it is likely that Hine’s Emerald had broader, less restricted wetland type requirements than those in which it is currently found. It is likely its habitat is very restricted now because the broader types have all been degraded to a higher degree, resulting in its current critically imperiled status. A somewhat broader description of habitat requirements of extant populations outside of Minesing Wetlands is found in the ORS4. The FRS appears to focus on the known Hine’s Emerald fen habitats in Minesing Wetlands and since fens are now rare in Ontario, the FRS may have mistakenly presumed fens and Hine’s Emerald were always rare in Ontario. However, limitations in the abilities and time of the field researchers who have surveyed Minesing Wetlands to find Hine’s Emerald larvae have resulted in only one larva being found in a crayfish burrow in one of the interior very rich sedge fens. The FRS seems to be prejudiced by the current rarity of these sedge fen habitats and appears to fail to consider that:
these habitats may not have been as rare historically,
Hine’s Emerald may have existed in Canada in other habitats which were not so rare but which may have been more vulnerable to degradation or destruction for Hine’s Emerald by human activity than these particular fen habitats in Minesing Wetlands

Science does not yet understand how the Minesing Wetlands still supports a Hine’s Emerald population despite the human activities in and adjacent to this habitat, nor does it know whether the larval habitat is restricted to the interior sedge fens or extends to the cattail and other vegetation type fens and marshes in Minesing Wetlands. Observations of adult Hine’s Emerald behaviour and activities in the cattail and mixed fens and marshes at the edge of Minesing Wetlands and beyond in the vicinity of the North Simcoe Rail Trail, Pinegrove Road and Baldwick lane suggest that these areas likely constitute critical larval habitats.

Based on the above arguments, and applying the precautionary principle of the SARA 2002, I suggest the Critical Habitat be extended to include all of the southeastern Minesing Wetlands and beyond to potential habitats from the vicinity of Pinegrove Road to the Minesing Wetlands.

Arguments to extend the proposed Critical Habitat of Hine’s emerald to all potential habitats in the Nottawasaga River watershed and adjacent watersheds

If the Hine’s Emerald was not historically precarious, then it is reasonable to suggest that the FRS will likely determine that recovery is feasible and require protection of a significant number of connected, protected habitats to achieve recovery. I recommend the Recovery Criteria of the USFWS RP 2001 should be considered by the FRS team as a model to be applied to the FRS. If it is accepted that the Hine’s Emerald was present throughout much of southern Ontario, then in order to recover the species to a secure population, particularly in light of the global climate change crisis and recognizing the primary threat to Hine’s Emerald is human development, a network of habitats will be required, close enough to provide dispersal support to each other, yet spatially and hydrogeologically independent and diverse enough to ensure no foreseeable single weather or other environmental or biological event can wipe out the species in Ontario. This would likely require that populations in several adjacent watersheds are required. The urgency here is that current, new and intensifying human development activities threaten the remaining wetlands and forests which may be required potential recovery habitats. Thus, if development is allowed to proceed, these habitats will be at the very least further degraded and at worst made unrecoverable by development, dooming the Hine’s Emerald and other associated SAR to extirpation from Canada in the long term. The good news here is that creating such diverse protection would not only protect and recover Hine’s Emerald, but a myriad of other living things, including our human population and turn our unsustainable socio-economic system around to create a balanced, thriving and sustainable socio-economic system. Again, the precautionary principle and the plight of all Species At Risk (SAR) and the global climate change crisis all implore us to take extreme and decisive action now to avert the predicted cataclysmic consequences of climate change if we continue to delay our action and continue “business as usual”.

While it appears likely that this Minesing Wetlands population may be the only extant Hine’s Emerald population in Canada, it is possible other now isolated populations exist, perhaps of lower population densities than the Minesing population, where positive search results are extremely difficult due to the low population density combined with the difficulty in surveying for this cryptic and elusive species. A very important aspect of this argument is that our historical thinking of the preservation of wetlands and other habitats has focused on the protection of the habitat from direct human activity within that habitat. NVCA 60 years 2014 report15 clearly shows the tremendous negative impact on Minesing Wetlands from both direct internal and indirect external threats in a recent 60 year period, during the latter half of which period the Minesing Wetlands has been so called protected, yet continues to decline. The health of the Minesing Wetlands is inextricably linked to the health of the vast Nottawasaga River watershed as a complex natural heritage system. In turn, the health of this system depends on the health of the adjacent watershed systems and on the climate system. The plight of the Hine’s Emerald, and of the other SAR, and the global climate change crisis, all implore us to stop our assaults on, and abuses of, these systems now, and to begin mitigation and remediation measures now. Let’s start with halting new development in the Nottawasaga River watershed and adjacent watersheds, and redirecting those energies to mitigating the negative impacts of our existing developments and toward remediating and restoring these natural heritage systems. The survival of our own species, and innumerable others, depends upon our immediate actions.

We need to make immediate and extreme changes to our socio-economic and cultural system in order to survive and arrest climate change. I implore the Government of Canada to use the Hine’s Emerald and the SARA 2002 legislation as a catalyst to take immediate action to minimize the loss of biodiversity and mitigate the impacts of climate change and the extent of climate change.

If we are able to redirect all of our energies, activities and resources from new development to mitigation and remediation activities, we will be mitigating, remediating and adapting to climate change. The SARA legislation is in place to do that now. Please enforce and implement the legislation immediately.

Thank you again for this opportunity to comment on the FRS. I would appreciate a direct reply to my comments, but I would accept a delay if you are going to take immediate action as I suggest.

Please feel free to consult with me for further clarification, comments or discussion. I would be happy to help revise this important FRS in any way I can. The future of the planet depends on it.

With sincere respect and gratitude,

Chris Evans

1(FRS) Environment and Climate Change Canada. 2019. Recovery Strategy for the Hine’s
Emerald (Somatochlora hineana) in Canada [Proposed]. Species at Risk Act Recovery
Strategy Series. Environment and Climate Change Canada, Ottawa. 3 parts, 27 pp. +
vi + 27 pp. + 5 pp.

2(COSEWIC 2011) COSEWIC Assessment and Status Report on the Hine’s Emerald Somatochlora hineana in Canada

3(SARA 2002) Species at Risk Act (S.C. 2002, c. 29), Canada

4(ORS) Pulfer, T.L., C.G. Evans, D. Featherstone, R. Post, J.I. McCarter and J.F. Laverty. 2013.
Recovery Strategy for the Hine’s Emerald (Somatochlora hineana) in Ontario. Ontario
Recovery Strategy Series. Prepared for the Ontario Ministry of Natural Resources,
Peterborough, Ontario. vi + 27pp.

5Evans, C.G., D. Featherstone, P. Hamr, R. Post, T.L. Pulfer. 2015. Hine’s Emerald
(Somatochlora hineana) dragonfly study in Minesing Wetlands: an investigation into the
habitat, species, associated species and threats.

6(SAR Policy 2016) Canada 2016, Species at Risk policy on survival and recovery 2016, Species at Risk Act Policies and Guidelines Series https://www.canada.ca/en/environment-climate-change/services/species-risk-public-registry/policies-guidelines/survival-recovery-2016.html

7(USFWS RP 2001) U.S. Fish and Wildlife Service. 2001. Hine’s Emerald Dragonfly (Somatochlora hineana)
Recovery Plan. Fort Snelling, MN. 120 p.

8(Riley 2013) The Once and Future Great Lakes – An Ecological History, John L. Riley 2013

9Protecting Southern Ontario’s Wetlands, Environmental Commissioner of Ontario, 2018 Environmental Protection Report

10 Pioneer Papers — No. 1., Simcoe County Pioneer and Historical Society, Barrie 1908

11Trophic Cascade https://www.britannica.com/science/trophic-cascade

12How Wolves Change Rivers https://www.youtube.com/watch?v=ysa5OBhXz-Q


14(Colin D. Jones et al 2013) Field Guide to The Dragonflies and Damselflies of Algonquin Provincial Park and the Surrounding Area, 2013 Algonquin FIeld Guide Series, The Friends of Algonquin Park

15(NVCA 60 years 2014) Rootham, S. and D. Featherstone. 2014. 60 years of forest change in the Minesing
Wetlands (1953-2013). Prepared for Nottawasaga Valley Conservation Authority and
Friends of Minesing Wetlands. 50 pp.


–USFWS RP 2001
-Refer to the “recovery criteria” for number of populations and habitats +
-SARA precautionary principle
-suggests Canada critical habitat protections be extended to identified potential habitats immediately and that all human development activities in Simcoe, Grey Huron and Bruce Counties be halted pending identification and protection of these potential habitats
-The USFWS RP 2001 anticipated that US recovery of the species could as soon as 2019, however, the species is still listed as Endangered in the US and the US rank is N2N3 (NatureServe 2019) “The Center for Biological Diversity in 2004 filed a lawsuit against the U.S. Fish and Wildlife Service to gain habitat designation for the Hine’s emerald dragonfly. The Center won the case two years later, but struggled when later the U.S. Fish and Wildlife Service took away over half the land allocated for the Hine’s emerald dragonfly by the year 2007. In 2009, the Center for Biological Diversity sued the U.S. Fish and Wildlife Service again over not including critical habitat land in Michigan and Missouri for the Hine’s emerald dragonfly. The Center won the case in 2010.” Wikipedia from “Hine’s emerald dragonfly”. www.biologicaldiversity.org. Retrieved 2017-09-23.
-recommend acquiring and studying USFWS 5 year reviews to gain knowledge of the successes and failures of the USFWS RP 2001 and use this information to inform the FRS on feasibility of recovering Hine’s Emerald in Canada and the best strategy based on the extensive studies and experience of the US Hine’s Emerald recovery efforts and research

–I have conducted recent and previous surveys5 of Snow Valley part of Minesing Wetlands on Crown Land and NVCA properties around George Parkway and found rare associated species, such as Clamp-tipped Emerald, and potential Hine’s Emerald fen habitat, extensive historical human disturbance within and adjacent to, and recent intensive development disturbance adjacent to and nearby on groundwater recharge area, invasive Phragmites australis ssp australis. Yet I have found no Hine’s Emerald adults there to date. This strongly suggests local extirpation or very low population density induced by human activities. Similarly, I have conducted surveys of Simcoe County Forest – Tiffin Tract and Smith Tract fens between Simcoe Road 27 and Gill Road5. This is a similar situation to Snow Valley, but with less, more distant suburban development, and the location is more remote, 9 km, from Minesing Wetlands, so limited direct dispersal and regeneration support to or from Minesing Wetlands due to human activity destruction or degradation of potential connecting wetlands and other human barriers such as roads and railway. Thus, it is not surprising Hine’s Emerald has not yet been found here given the human disturbance to connecting wetlands and forests between this site and Minesing Wetlands. Natural regeneration of this habitat and some of the potential interconnecting habitats appears to be in progress. Yet, the Midhurst Secondary Plan proposes a very large scale, 10,000 home, urban development adjacent to this area on the aquifer recharge area, including municipal wells. On a smaller scale, these conservation areas are undergoing
–Hine’s Emerald was first described to science by Williamson in 1931 from specimens from the USA. (COSEWIC 2011)2
–Extirpated, from Ohio and Indiana. Known now from Illinois, Michigan, Missouri and Wisconsin. Declared Endangered in USA January 1995, subsequent discovery in Missouri in 1999 (USFWS RP 2001) & https://www.krcu.org/post/discover-nature-hines-emerald-dragonfly#stream/0
–Targeted surveys for Hine’s Emerald in Canada at potential sites based on USA habitat criteria from 1999 to 2002 (COSEWIC 2011)
–Hine’s Emerald was first discovered in Canada in Minesing Wetlands in June 2007. This area was not considered to be potential habitat in the earlier search efforts because it was atypical of the restrictive “known” present day habitats of Hine’s Emerald in the United States of America. (ORS)3 While it is wise to focus search efforts on the most likely current restricted Hine’s Emerald habitat types, the danger is that this leads to the false presumption that the historical habitats were restricted to this type, thus, potential broader habitats which may have recovered or have been somehow sheltered from human impacts may be overlooked
–Subsequent aerial searches in potential habitats near and far have not yet had positive results. This suggests all of the Hine’s Emerald habitats in southern Ontario may have been negatively impacted by human development and supports the assertion that human development activities are the primary threat to Hine’s Emerald (USFWS RP 2001)
–“The evidence so far suggests that these dispersal events were relatively recent (approximately 4000 years ago during the Pleistocene age) leading experts to suggest that dispersal distances would be larger than the current observed maximum distance (5.4 km). ” (ORS Dispersal section)
–From changed historical context to not precarious, FRS must be completely reviewed to:
-enhance protections for known extant populations
-to immediately halt development activities in Simcoe, Grey, Huron and Bruce counties pending identification of all potential Hine’s Emerald habitats
-to immediately extend enhanced critical habitat protection to all identified potential habitats
–Wikipedia “Michigan’s known sites of Hine’s emerald dragonfly are in Mackinac, Alpena, and Presque Isle counties.” and “The largest breeding population known is in Door County, Wisconsin”
–“It had been suspected that Hine’s Emerald may be present in Ontario due to the presence of similar habitats found at known sites in the United States. This led to targeted surveys between 1999 and 2002, all of which resulted in negative findings (COSEWIC 2011).” ORS
–“Twenty-eight other sites that were identified as having appropriate habitat were searched (see COSEWIC 2011 for details). Although Hine’s Emerald have not been found at these sites to-date, it should be noted that negative survey results are not uncommon for this species where it is extant (COSEWIC 2011). Experts suggest there is a high likelihood of extant Hine’s Emerald populations at least at some of these twenty-eight locations. Further surveys are necessary to investigate this possibility. ” ORS
–“There are additional sites, mostly in Bruce County and Manitoulin District with habitat that is potentially suitable to Hine’s Emerald. Most of these sites have received sampling effort targeted at Hine’s (see above section on Search Effort) but these surveys have not revealed its presence. As discussed in earlier sections, however, negative search results need to be interpreted with caution. It is possible that this species does occur at other sites, but the total number of additional sites, if there are, in fact, any, are probably few. ” (COSEWIC 2011)
–Southern Ontario is the most densely populated and intensively developed area in Canada. (https://en.wikipedia.org/wiki/Southern_Ontario)
–We must get off addiction to fossil fueled growth economy – climate change and species extinctions/loss of biodiversity (ESA 2007)
–Must redirect growth energies and resources to a sustainable and spiritually balanced social, cultural, economy and society
–Taproot Root Cause analysis suggests SARA is not getting at the root cause of the problem. We are spending time and money fighting fires, but the key causal factor is fear. We fear the loss of our social, economic and cultural addiction to our unsustainable materialist growth economy. This fear comes from our spiritual ignorance. TapRooT® System https://www.taproot.com/about/
–Are any FRS team Hine’s emerald experts comparable to USA
–Were any USA experts consulted on the draft FRS?
–I tried to initiate a review of ORS & GRS due to USA expert who identified the lack of recovery habitats in the ORS. In my inexperience I failed to note this in the ORS, naively assuming Hine’s Emerald was secure in MW and then, once I read the USA expert criticism, I failed in my attempts to persuade MNRF to review this important oversight. Refer to this link containing my petition to MNR Minister in 2014…

Petition to the Minister of Natural Resources David Orazietti

———- Forwarded message ———-
From: Chris Evans <xxx@xxx>
Date: 22 February 2014 21:52
Subject: Urgent Request regarding immediate threats to the persistence of the Endangered Hine’s Emerald dragonfly in Ontario
To: minister.mnr@ontario.ca
Cc: minister.moe@ontario.ca, minister.mah@ontario.ca, warden@simcoe.ca, wkolodziechuk@dufferincounty.ca,warden@grey.ca, Byron Wesson <bwesson@nvca.on.ca>, Dave Featherstone <dfeatherstone@nvca.on.ca>, Ryan Post <rpost@nvca.on.ca>, Tanya Pulfer <tanyap@ontarionature.org>, Jennifer McCarter <Jennifer.McCarter@natureconservancy.ca>, “Jolene Laverty, M.Sc.” <jolenelaverty@gmail.com>

February 22nd, 2014

Honourable David Orazietti
Minister of Natural Resources – MINISTER’S OFFICE
Whitney Block, 6th Flr Rm 6630
99 Wellesley St W
Toronto ON M7A1W3

Dear Minister Orazietti:

The Hine’s Emerald dragonfly was listed under the Ontario Endangered Species Act, 2007 as Endangered on January 13th, 2012.

Its only known extant population in Canada is in the Minesing Wetlands in Springwater Township, Simcoe County, The Nottawasaga River watershed, Ontario.

It is in imminent danger of extirpation from Ontario.

The main threat to its persistence in Ontario is damage to its habitat by human development.

It is currently completely surrounded by human development.

Since its listing as Endangered:
a human development of 660 homes (Stonemanor Woods, OPA 28) has begun construction in the Snow Valley Uplands, the very source of groundwater which is essential to this species’ existence
human developments along Snow Valley Road, impacting the same groundwater source have been under construction and are nearing completion
human development in the City of Barrie is under construction and stormwater drainage will flow into Little Lake and thence to Willow Creek and thence into the heart of the only known habitat of the Hine’s Emerald, the Minesing Wetlands
extensive and intensive human development projects have recently been completed, are currently under construction, are pending approval or are in the planning stages throughout the Nottawasaga River watershed, which drains through the heart of the Minesing Wetlands
human development of 6,496 housing units in the village of Midhurst (OPA 38) within the Willow Creek watershed is pending approvals

To my knowledge, to date none of the proponents of or the approvals for the human development projects listed above had any knowledge of the potential impacts of these projects on the Endangered Hine’s Emerald dragonfly.

On behalf of the Hine’s Emerald dragonfly and on behalf of the precious biodiversity of all other living things in the Minesing Wetlands, I make the following respectful request:
Under the authority of the Ontario Endangered Species Act, 2007, “with appropriate regard for social, economic and cultural considerations”1, please consider taking immediate action to “avoid or minimize”1 the main threat to the persistence of the Hine’s Emerald dragonfly in Ontario by halting all active, pending or planned human development projects in the Nottawasaga River watershed.

May I suggest you consider looking for guidance and inspiration in the eloquent preamble of the Endangered Species Act, 2007, as I have done in preparing this request?

Thank you for your consideration of my request.

With Deepest Respect,

Christopher G. Evans
Co-author of the “Recovery Strategy for the Hine’s Emerald in Ontario”

1 Preamble, Ontario Endangered Species Act, 2007

My concerns were dismissed as “The province does not have an appetite for review of the ORS or GRS at this time and you will have to wait for the 5 year review.” The 5 year review was delayed by over a year due to budget and resource issues, and then I had no opportunity to comment. I know of no evidence that the review seriously considered any new evidence which the Ontario government received from their limited Recovery Strategy Actions, nor whether it considered the USA expert’s criticism, nor to petitions from the Environmental Commissioner “Small Things Matter” http://docs.assets.eco.on.ca/reports/environmental-protection/2014-2015/2014_2015-AR.pdf
-Ontario hed papers? NVCA Ryan Post et al, Tanya Pulfer et al
-US papers on ontario habitats? none that I know of
-Any surveys by larval and aerial HED experts in Ontario?
-Historical wetland assessment is likely conservative and coarse and likely underestimates the type and size
-Wetland loss estimates likely do not include degraded functionality of wetlands. i.e. it only shows wetlands known in 1800 which were drained and or otherwise destroyed since then. These estimates do not include wetlands not known in 1800, nor those already destroyed prior to 1800. Nor does the estimate consider degradation of the remaining wetlands. Also consider southern Ontario forest loss was in the range of 80% to 90%. (Riley 2013) Thus, actual habitat destruction and loss of functionality for Hine’s Emerald likely far exceeded 80% due to human activities in southern Ontario.

Include in submission but separate from science, use for inspiration
-Extirpations of still unknown species are likely to have already occurred
-Many rare species not yet assessed by COSEWIC or officially listed as SAR are likely endangered but there are so many there aren’t resources to list them all
-Likely there are more rare unknown species like Hine’s Emerald which have yet to be discovered, but it may be too late
-“Native Wisdom for White Minds” by Anne Wilson Schaef quotes related to lack of spiritual knowledge, respect for the unknown, etc. September 20th, etc. Sept. 24th specifically!
-Anne Wilson Schaef often heard Elders from a wide variety of Native Peoples say, “Our legends tell us that a time will come when our wisdom and way of living will be necessary to save the planet, and that time has come.” Anyone ready to move from feeling separate to a profound sense of connectedness, from the personal to the global, will find the path in this mind-expanding book.
-From the cover of the book by Anne Wilson Schaef, PH.D. Native Wisdom For White Minds – Daily Reflections Inspired by the Native Peoples of the World, Toronto: Random House of Canada Limited, 1995.
-Albert Schweitzer – “Until he extends his circle of compassion to include all living things, man will not himself find peace.” If I draw back from the plight of our species at risk and the many organisms which are now extinct due to human activities, and from the global crisis of climate change, I see that the root cause (TapRooT® System) of these problems is that mankind’s circle of compassion does not include all living things. Let us begin to help each other to extend our circle of compassion to include all living things.

“regulatory capture”
From Charles Seife’s chapter entitled “Capture”, in What Should We Be Worried About?, John Brockman ed., 2013, Edge Foundation Inc.

In the 1970s, economists, led by future Nobel laureate George Stigler, began to realize that [regulatory capture] was the rule, not the exception. Over time, regulatory agencies are systematically drained of their ability to check the power of industry. Even more striking, they’re gradually drawn into the orbit of the businesses they’re charged with regulating. Instead of acting in the public interest, the regulators wind up as tools of the industry they’re supposed to keep watch over. This process, known as “regulatory capture,” turns regulators from watchdogs into lapdogs.

Species at Risk Act
S.C. 2002, c. 29

Assented to 2002-12-12

An Act respecting the protection of wildlife species at risk in Canada

Recognizing that

Canada’s natural heritage is an integral part of our national identity and history,

wildlife, in all its forms, has value in and of itself and is valued by Canadians for aesthetic, cultural, spiritual, recreational, educational, historical, economic, medical, ecological and scientific reasons,

Canadian wildlife species and ecosystems are also part of the world’s heritage and the Government of Canada has ratified the United Nations Convention on the Conservation of Biological Diversity,

providing legal protection for species at risk will complement existing legislation and will, in part, meet Canada’s commitments under that Convention,

the Government of Canada is committed to conserving biological diversity and to the principle that, if there are threats of serious or irreversible damage to a wildlife species, cost-effective measures to prevent the reduction or loss of the species should not be postponed for a lack of full scientific certainty,

responsibility for the conservation of wildlife in Canada is shared among the governments in this country and that it is important for them to work cooperatively to pursue the establishment of complementary legislation and programs for the protection and recovery of species at risk in Canada,

it is important that there be cooperation between the governments in this country to maintain and strengthen national standards of environmental conservation and that the Government of Canada is committed to the principles set out in intergovernmental agreements respecting environmental conservation,

the Canadian Endangered Species Conservation Council is to provide national leadership for the protection of species at risk, including the provision of general direction to the Committee on the Status of Endangered Wildlife in Canada in respect of that Committee’s activities and general directions in respect of the development, coordination and implementation of recovery efforts,

the roles of the aboriginal peoples of Canada and of wildlife management boards established under land claims agreements in the conservation of wildlife in this country are essential,

all Canadians have a role to play in the conservation of wildlife in this country, including the prevention of wildlife species from becoming extirpated or extinct,

there will be circumstances under which the cost of conserving species at risk should be shared,

the conservation efforts of individual Canadians and communities should be encouraged and supported,

stewardship activities contributing to the conservation of wildlife species and their habitat should be supported to prevent species from becoming at risk,

community knowledge and interests, including socio-economic interests, should be considered in developing and implementing recovery measures,

the traditional knowledge of the aboriginal peoples of Canada should be considered in the assessment of which species may be at risk and in developing and implementing recovery measures,

knowledge of wildlife species and ecosystems is critical to their conservation,

the habitat of species at risk is key to their conservation, and

Canada’s protected areas, especially national parks, are vital to the protection and recovery of species at risk,

NOW, THEREFORE, Her Majesty, by and with the advice and consent of the Senate and House of Commons of Canada, enacts as follows:” end quote

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