OFA provides comments to the Ministry of Environment, Conservation and Parks, Species at risk recovery unit, regarding the requesting additional scientific information to be considered in preparing the recovery strategy for Spoon-leaved Moss. OFA acknowledges that actions need to be taken to minimize impacts on species at risk and their habitats, however recovery strategies, government response statements and habitat regulations need to reflect the reality that a single-minded focus on species restoration to the exclusion of all other factors is unsustainable. The context for OFA’s landscape perspective is based on Ontario’s ever-shrinking supply of agricultural land. OFA supports the proposed recovery goal and the proposed actions to support research, monitoring, and addressing key knowledge gaps for Spoon-leaved Moss. However, OFA would like to highlight that much of the proposed recovery strategy is based upon inference, and that scientific knowledge on the biology or ecology of Spoon-leaved Moss, or the reasons for its rarity is limited.
The Committee on the Status of Endangered Wildlife in Canada (COSEWIC) assessment and status report on Spoon-leaved Moss in 2017 list agriculture’s threat impact as “unknown”. OFA requests this section be revised to accurately reflect that more information is needed to determine the effects agricultural activities have on Spoon-leaved Moss colonies in Ontario. OFA supports that the proposed Recovery Strategy emphasizes monitoring, management, research, and promoting awareness of the species. However, we are concerned that areas being considered in developing a habitat management plan and future habitat regulations for Spoon-leaved Moss may potentially limit agricultural activities. OFA recommends that future habitat management plans and habitat regulations exclude boundary Ecosites where agricultural activities occur, and do not impede normal farm practices.