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Summary of comments Canada Gazette Part I, October 23, 2004

Proposal to add species to Schedule 1 of the Species at Risk Act (SARA)


Following initial consultations the proposed Order Amending the List of Wildlife Species was published in the Canada Gazette, Part I on October 23, 2004 for a final, 30-day comment period that ended on November 22nd, 2004 (http://www.registrelep-sararegistry.gc.ca/document/default_e.cfm?documentID=576 ). Please note the information contained in the Response is still subject to change pending the final recommendations by the Minister to the GIC in the upcoming weeks.

Summary of Submissions

Proposal to add species to Schedule 1

  • It was requested that the Margined Streamside Moss be listed as extirpated, rather that endangered as assessed by COSEWIC, because it has not been seen in the wild for 27 years (since 1977). It was also requested that the Dromedary Jumping Slug and the Warty Jumping Slug be considered as data deficient and not be added to Schedule 1, because of scientific uncertainty.
  • It was also requested that the Minister of the Environment refer back to COSEWIC the Polar Bear, the Northwestern population of Grizzly Bear and the Western population of Wolverine on the basis that community and aboriginal traditional knowledge were not fully considered during the assessment process, and that consultations on the proposal to add these species to Schedule 1 have not been sufficient.
  • It was also requested that the Polar Bear not be added to the list on the basis that existing conservation and management plans are adequate to address recovery for this species. Similarly, it was suggested that the western population of Wolverine should not be listed at this time because, with a few exceptions, their population is stable to increasing.


  • In accordance with COSEWIC criteria, for a species to be assessed as extirpated, the species must not have been seen in the wild for 50 years. While there is some scientific uncertainty, the assessments for both the Dromedary Jumping Slug (threatened) and the Warty Jumping Slug (special concern) are consistent with COSEWIC criteria.
  • The Minister of the Environment is considering recommending not listing the Polar bear, the Northwestern population of Grizzly bear and the Western population of Wolverine in order to consult further with the Nunavut Wildlife Management Board regarding concerns they raised with respect to the assessment and listing process.

Proposal not to add Cultus and Sakinaw sockeye salmon to Schedule 1 and to refer speckled dace back to COSEWIC

  • A number of individuals and groups are critical of these proposed decisions, and believe that the estimated costs from listing the sockeye populations are exaggerated and that not listing will cause these populations to become extinct. On the other hand many individuals and associations, primarily from the fishing industry sector, feel that the estimated costs are understated, and that listing these populations would bring significant negative socio-economic consequences to the commercial fishing sector and coastal communities of British Columbia.
  • A few individuals and organizations have suggested that the Speckled Dace should be added to the list because, in their view, new information has become available that may result in a change to the status of the species.


  • The Cultus and Sakinaw populations of Pacific sockeye salmon may not be listed because of the unacceptably high social and economic costs that the commercial fishing and recreational fishing sectors, some Aboriginal peoples, coastal communities and others would face if these species were added to Schedule 1. Cultus and Sakinaw sockeye have not been relegated to extinction. On the contrary, Fisheries and Oceans Canada have already launched approximately $1 million of initiatives to protect and rebuild these populations and will continue to aggressively pursue this action plan.
  • When COSEWIC made its assessment of Speckled Dace in 2002, it placed significant weight on a proposed hydroelectric dam that it believed could lead to a 22 per cent loss of habitat. The proposed dam has since been redesigned to lessen the impact on habitat by two-thirds. As well, several points in the COSEWIC Status report require further documentation and consideration to clarify the biological basis for the assessment.