AWA Response to Environment Canada on proposed Amended Recovery Strategy for Sage-grouse: “Plan does not go far enough”

On Feb. 16, AWA sent the attached response to Environment Canada regarding their proposed Amended Recovery Strategy for the Greater Sage-Grouse (Centrocercus urophasianus urophasianus) in Canada. The response was formulated in close consultation with numerous scientists and experts on the greater sage-grouse, and we are confident that it represents the best possible position based on current science and knowledge about the species.

AWA’s primary concerns about the plan include, but are not limited to:

• Accountability – we are concerned that there is not enough accounting of measures introduced in earlier recovery strategies for the greater sage-grouse, including any indication of what has or has not worked.
• Lack of Urgency – the 2013 proposed Amended Recovery Strategy does not adequately reflect the urgency of the need to implement greater sage-grouse recovery actions on the ground immediately. Specifically, the fact that without dramatic changes to habitat loss and active habitat restoration, there will be no greater sage-grouse in Alberta or perhaps in Canada within 2-3 years is not recognized in the plan.
• Population and Distribution Objectives – while we commend the inclusion of clear and measurable population and distribution objectives, AWA does not agree with the reduction in the number of active leks being called for in Saskatchewan from 30 (in the 2008 Recovery Strategy) to 20, as we do not believe that is sufficient to support the stated population objective.
• Threats to Greater Sage-grouse Survival – AWA believes that the identification of threats to greater sage-grouse survival in the 2013 proposed Amended Recovery Strategy is inadequate and inconsistent with the requirements of the federal Species at Risk Act (SARA).
• Voluntary versus Prescriptive Recovery Measures – while voluntary and stewardship approaches have a role to play, given the imminent threats to the survival of greater sage-grouse in Canada we believe prescriptive tools are as important or more important and that the Amended Recovery Strategy should clearly state this.
• Critical Habitat – while the identified critical habitat is a good start, we do not believe it will be sufficient to achieve the stated population and distribution objectives of the proposed Amended Recovery Strategy. Additional critical habitat is needed; this can and should be identified now. In addition, the plan should include a clear explanation of how the identified critical habitat reflects a precautionary approach, as required under SARA.
• Buffer Zones – to maintain the capacity of year-round critical habitat to support greater sage-grouse life processes, a minimum buffer of 1.9 km is needed around all identified year-round critical habitat. AWA would like to see the Amended Recovery Strategy acknowledge and designate these buffer zones.
• “Seasonally” Harmful Activities – restricting activities only during the mating season and leking hours will not adequately prevent destruction of critical habitat. Noise restrictions should be applied during all hours and to year-round as well as lek critical habitat from the onset of leking to the end of brood-rearing, to mitigate the effects of noise and visual disturbance.
• Inadequacy of the Level of Ambition in the Plan – AWA has serious misgivings about the overall lack of ambition in the 2013 proposed Amended Recovery Strategy. In our opinion the strategies, approaches and actions outlined are insufficient to ensure greater sage-grouse survival in Canada. For example, it is important that the federal Amended Recovery Strategy supports the goals of the Alberta Greater Sage-Grouse Recovery Plan 2013-2018 and sets a precautionary and scientifically sound basis for greater sage-grouse management.
• Lack of details on Financial Support for Implementation – the strategy gives no indication of where funding support will come from to support the socio-economic consequences of implementing this strategy. There is thus no financial incentive to landowners to do the right thing; there is no indication if there is a plan that industry will be compensated for reduced activity.

These comments and careful review are based in AWA’s passion and concern for the legacy of wilderness and wildlife that we will leave for future generations and on our understanding of the best available science relevant to greater sage-grouse survival and recovery. We look forward to opportunities to work with Environment Canada as we continue to develop the Sage-grouse Partnership we initiated in March of 2013.