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Please send this letter to Environment Canada, Ontario's Ministry of Natural Resources and Fort Erie Mayor and Town Council and ask them to save Lake Erie's Toads by revoking the Molinaro Group's building permits! The letters are part of a call for comments that ends March 10th, so please send and then ask your friends to do the same. www.savethetoads.com/toads-letter
In December 2011, 1,717 SAVE THE FROGS! supporters sent letters to the Ontario government urging them to deny construction permits to developers in the town of Fort Erie, Ontario. The developers plan to build a non-essential 12-story condominium and shopping complex on top of Fowler's Toad habitat at Crystal Beach on the shores of Lake Erie. The toads are protected under Ontario's Endangered Species Act, and construction of the building would undoubtedly cause irreparable harm to the toad population, which is one of the last that remains in Canada. Unfortunately, the Ontario Ministry of Natural Resources (phone: 905-562-4147) recently approved the permits. To make matters worse, they completely disregarded our comments and failed to change even a single line of the permitting requirements, giving the developers free rein to "damage and destroy" the toad's habitat and to "harm, harass, kill, and collect the toads".
Let's fight this! Canada should not be driving one of their last Fowler's Toad populations to extinction so that people can live in holiday homes next to the water. These toads are guaranteed to have their homes destroyed if we do nothing. Please do not assume anyone else is donating much for this campaign...we have only raised about $900 so far -- not much considering the developers have millions!! We can only run this campaign with your financial support, so please make the most generous tax-deductible donation you can afford, and let's SAVE THE FOWLER'S TOADS! Thank you so much for donating and being a role model for all those around you!
"Lake Erie is my backyard! We can't allow this to happen!"
In Spring 2013, students of SAVE THE FROGS! Academy held a course focused on protecting the toads. Watch the videos here:
Please download the PDF of this flyer, send it to friends in Canada, and post a few around your town or school.
A note from SAVE THE FROGS! Founder Dr. Kerry Kriger:
On top of all the well-known reasons to save amphibians, there's one more significant reason. I grew up with toads all around: they were a part of my life for two decades. I found the Fowler's Toad pictured below in my parents' front yard in 2004, the same summer I conceived SAVE THE FROGS!. What if I had never seen a toad because humans had killed them all? Maybe I never would have cared about amphibians and this entire SAVE THE FROGS! movement would never have come into existence. How much hope for saving the frogs would there be on this planet without SAVE THE FROGS!? I personally have no doubt that most frogs would be doomed to extinction. Every time we lose an amphibian population, we lose the potential to produce humans who are actually inspired enough to take action to save the planet, and thus we slip that much further into the vicious cycle of environmental decay. These toads matter, so please help us save them by donating today! Just email us afterwards and ask us to direct your donation to the toads.
These comments were submitted by SAVE THE FROGS! Founder Dr. Kerry Kriger in March 2013:
"I am writing with regards to the Fowler's Toad Recovery Strategy, the goal of which is to protect Fowler's Toads and increase the toads' population size. Specifically, I am writing to ask you to revoke the Molinaro Group's permits for the proposed construction of a 12-storey condominium building on the Crystal Beach shores of Lake Erie (http://savethefrogs.com/toads). Habitat destruction is the number one cause of amphibian population declines worldwide, and thus it is of utmost importance that Canadian federal, provincial and local governments protect amphibian habitat. Permitting the Molinaro Group to "damage and destroy" Fowler's Toad habitat and to "harm, harass, kill, and collect the toads" is thoroughly unethical. Furthermore, no overall benefit to the species can be expected within any reasonable timeframe and thus such permits are in direct violation of Ontario's Endangered Species Act.
I know of no published studies that demonstrate an increase in Fowler's Toad population size due to habitat destruction. The Molinaro Group's proposed building would undoubtedly destroy and degrade Fowler's Toad habitat through (1) outright destruction of habitat due to construction of parking lots, roads and the building itself; (2) increased car and foot traffic in the vicinity; (3) increased noise and light pollution; (4) construction activities that require heavy equipment for months on end; (5) through altered water flow due to the increase in permeable surfaces; (6) changes in the soil structure, which impedes burrowing by the toads; and (7) increased human trash and chemical runoff from vehicles. It is unfathomable to believe that the mitigation strategy that has been approved by the Ontario government would yield any "overall benefit" to the species -- as is required by law for the permits to be issued.
Fort Erie's Fowler Toads chose their current breeding, foraging and shelter sites for a reason, and no human on the planet knows more about how to increase those Fowler's Toads chances of reproductive success than do the toads themselves. Thus it is naïve to accept the developer's claim that building artificial sand dunes will provide a benefit to the toads. Canada is one of the world's least densely populated countries and there is ample non-critical habitat on which to build, yet reasonable alternatives such as building further from the shore have apparently not been considered. Furthermore, there are almost certainly many vacant buildings in which to put living units, gift shops and restaurants. Why not take advantage of those buildings and in doing so also reduce the amount of natural resources and related environmental destruction required to build a 12-storey building?
Amphibians are rapidly disappearing worldwide and over 2,000 species are already threatened with extinction. Ontario's Endangered Species Act protections were enacted for a reason and should not be disregarded solely for human convenience (in this case so that wealthy humans can have lakeside views and developers can increase their profits). Doing so would set a dangerous precedent and would undoubtedly tarnish Canada's reputation as a respected world leader. Fortunately the building construction has not yet begun, and thus I urge you to take advantage of this opportunity and act in a way that will mark Fort Erie, Ontario and the whole of Canada as leaders in wildlife conservation. The world is watching, and this is Canada's single greatest opportunity to support amphibian conservation efforts and protect Canada's wildlife for future generations of humans.
In conclusion, I strongly urge you to revoke the permits for any activities at Crystal Beach that include the construction of non-essential buildings on or near Fowler's Toad habitat and I urge you to see www.savethefrogs.com/toads for more information on the threats amphibians face and the importance of protecting remaining amphibian populations.
Thank you for your consideration."
On Monday November 19th, 2012 I spoke with Fort Erie's Mayor Doug Martin, a vocal supporter of the proposed building complex. This is my followup email to him:
"Dear Mayor Martin,
Thanks for calling me this morning to discuss the toads and humans
that would be affected by the proposed Crystal Beach development.
My main concerns are:
(1) The Ontario Ministry of Natural Resources has authorized the
Molinaro Group to "damage and destroy" the toad's habitat and to
"harm, harass, kill, and collect the toads". It would be unfathomable
to think that a government would ever authorize humans to do the
above-mentioned acts to another group of humans, and thus it is
hypocritical to authorize or permit such activities to be done to
toads. These statements in the permit also imply that some or all of
these acts will indeed come to pass should the construction of the
condominium/shopping complex take place. So long as such acts of
violence are permitted against the toads, it is difficult for me to
envision supporting the development.
(2) No "net benefit" to the species will be achieved because humans do not know as much about optimal toad breeding habitat as do toads and therefore those toads that get harmed, harassed, killed, collected or have their habitat damaged and destroyed will not be able to replenish or increase in numbers using the proposed man-made habitat. To make matters worse, the maintenance of man-made habitat tends to be short-term and natural ecological processes quickly alter habitats, often rendering them unsuitable to the target species after only a couple years. Also, the educational proposals in the current permit (e.g. putting a sign near the toad habitat) will only provide negligible benefit to the toads and could be greatly improved. I strongly suggest that Ontario, the Molinaro Group and the town of Fort Erie create a long-term fund specifically dedicated to amphibian
education, similar to what the town of Cheongju, South Korea did when they disregarded the desires of 2,000 protesters and destroyed Asiatic Toad habitat. As one of the world's most respected and accomplished amphibian educators, I would be happy to advise on such a project.
I am currently organizing a public meeting in Fort Erie to bring
together, politicians, developers, scientists and concerned members of the public, so that we can have an open discussion on these issues. I invite you and the other council members to attend. This will likely take place in mid-April. You can stay up to date with our efforts at: www.savethefrogs.com/lake-erie-toads
Thanks for your consideration,
These comments were submitted by SAVE THE FROGS! Founder Dr. Kerry Kriger to the Ontario Ministry of Natural Resources and Fort Erie's Mayor Doug Martin on 27-December-2011:
As the Founder & Executive Director of SAVE THE FROGS! and as a professional ecologist with a Ph.D. in Environmental Science, I am writing to ask you to deny permits for the proposed construction of a 12-storey condominium building on the Crystal Beach shores of Lake Erie, as the building would undoubtedly destroy Fowler's Toad habitat. Amphibians are rapidly disappearing worldwide and over 2,000 species are already threatened with extinction. Fowler's Toads are protected as a Species At Risk under Ontario's Endangered Species Act. Such protections were enacted for a reason and should not be disregarded solely for human convenience (in this case so that wealthy humans can have lakeside views and developers can increase their profits).
Rather than tarnishing the reputations of both the town of Fort Erie and the government of Ontario by condoning the unnecessary destruction of wildlife habitat, I urge you to take advantage of this opportunity and act in a way that will mark Fort Erie and Ontario as leaders in wildlife conservation.
On top of it being thoroughly unethical to permit the destruction of Fowler's Toad habitat on Fort Erie's shores, the legal requirements set out in clause 17(2)(c) of the ESA have not been satisfied, and thus the Minister should under no circumstances authorize any person to engage in the proposed activities, which are prohibited by section 9 or 10 of the ESA.
(i) No overall benefit to the species will be achieved within a reasonable time through the conditions of the permit. It is unfathomable to think that building a business or residential complex on top of toad's homes will provide a benefit to the species. Fort Erie's Fowler Toads chose their current breeding, foraging and shelter sites for a reason, and no human on the planet knows more about how to increase those Fowler's Toads chances of reproductive success than do the toads themselves. Thus it is naïve to accept the developer's claim that building artificial sand dunes will provide a benefit to the toads.
(ii) Reasonable alternatives that would not negatively affect the species (i.e. building elsewhere) have apparently not been considered. The proposed condominium would undoubtedly negatively affect the species. Canada is one of the world's least densely populated countries and there is ample non-critical habitat on which to build. Furthermore, there are almost certainly many vacant buildings in which to put living units, gift shops and restaurants. Why not take advantage of those buildings and in doing so also reduce the amount of natural resources required to build a 12-storey building?
(iii) The conditions of the permit do not appear to contain reasonable steps that would minimize the negative effects on individual members of the species to any acceptable levels:
- Conducting the activity in an alternative location would be optimal but is not part of the proposal;
- "Using alternate methods, equipment, designs, etc for carrying out the proposed activity" is unlikely to protect toads as the final result remains the same: a building on top of their homes;
- "adjusting timelines to avoid species-specific sensitivities (e.g., active periods for the species)" is unlikely to protect toads as the final result remains the same: a building on top of their homes;
- "any other alternative approaches that address adverse effects (in both the short and long term) on the specific protected species and habitat present on and/or surrounding the proposed activity location"; this statement offered in the Call For Comments is vague and does not provide any clues as to how the threatened toads would be protected.
- "implementing timing windows to avoid all construction activities during sensitive periods of the toad lifecycle" is unlikely to protect toads as the final result remains the same: a building on top of their homes;
- "installing barrier fencing around construction sites to keep toads away from harm" is akin to saying that merely evacuating the human occupants of an apartment building from their apartments prior to demolishing their building would cause those humans no undue harm or stress;
- "conducting nocturnal surveys to ensure no toads are trapped inside the barrier fencing and moving individuals encountered to a safe location": the premise of this statement is that the toads will indeed lose their habitat. As stated earlier, that is unacceptable;
- "educating construction personnel about Fowler's Toad and how to report sightings to MNR; and": I strongly support education of all Canadians regarding amphibians and urge the Canadians federal, provincial and local governments to initiate amphibian education programs at all levels of society.
- "installing educational signage in the area about toads and how to avoid harming them." Again, I support amphibian education programs, but it would be far-fetched to think that the problems incurred by the toads having their homes destroyed would be offset by educational signage in the area surrounding their new makeshift, lesser-quality, reduced-area home -- not to mention hypocritical, as the signs would have been erected by the very same people who caused or permitted the destruction of the toads' original homes.
Potential approaches to achieve an overall benefit for Fowler's Toad as suggested are unlikely to actually provide any overall benefit relative to simply leaving the toads be in their current habitat:
- "creating areas of dune habitat and plant with dune grasses and native shrubs to enhance toad habitat": as stated earlier, man-made structures will be unlikely to improve upon the toads' current habitat choice. Furthermore, the decrease in total habitat available to Crystal Beach's toads will undoubtedly result in crowded, stressful conditions for the toads;
- "installing rope fencing to protect this area from pedestrians and creating a no-raking zone": this statement implies that raking and walking around toad habitat is bad for the toads, so it is not difficult to envision the relative effect that building a 12-storey building directly on top of the toads' habitat will have, not to mention the increased number of humans trampling the surrounding habitat. Additionally, you must consider the light and sound pollution that will be emitted from the building and its human occupants, which will undoubtedly alter the toads diurnal/nocturnal cycles and drown out the male toads' mating calls.
- "building a boardwalk above and over Fowler's Toad habitat to minimize public disturbance while providing cover and shade for toads": Again this statement implies that humans walking can disturb toads, so it is easy to see that erecting a 12-story structure on top of Crystal Beach's Fowler Toads will cause significantly more irreversible damage. Furthermore, just as no human wants the tenant in the apartment above them walking loudly on the floor, toads do not likely want humans walking above them.
- "creating sand mounds with a 3:1 slope as a transition area from the public beach to the protected dune habitat"; the toads do not seek a runway to the public beach, they only want peace and for humans to build elsewhere. Such sand mounds will in no way provide any overall benefit to the Fowler's Toads.
- "designing shore wall protection structures to enhance Fowler's Toad habitat": I have never heard about toads anywhere in the world that prefer walls to natural lake shores. Please do not build any such walls.
- "undertaking a public education program about Fowler's Toad": as stated earlier, I support amphibian education programs and highly urge you to initiate Save The Frogs Day education campaigns in Fort Erie; in Canadian government offices; and throughout Canada on the 4th Annual Save The Frogs Day, April 28th 2012 (www.savethefrogs.com/day), which is the world's largest day of amphibian education and conservation action.
In conclusion, I strongly oppose your permitting any activities at Crystal Beach that include the construction of non-essential buildings on or near Fowler's Toad habitat and I urge you to see www.savethefrogs.com for more information on the threats amphibians face and the importance of protecting remaining amphibian populations.
Thank you for your consideration.
Sincerely, Dr. Kerry Kriger"
"Hello Dr. Kriger, I want to thank you very much for the effort you put forth in raising awareness for the land development in Fowler's Toad habitat. Your letter was exceptionally well written and the news of the response from SAVE THE FROGS members is incredibly encouraging. Much success for the year 2012, with the utmost sincerity."
- Patrick Moldowan, University of Guelph
We think this habitat looks nice as is, and doesn't need an environmentally destructive, visually unappealing condominium complex on it. What do you think?
Thanks to Sue Weidemann for the photos!
Mackenzie and Melanie Oudshoorn and friend Emily
Dr. Alan Byron
Marie A. Janicke, Ph.D
Storm Morgan & Earthsinger Designs
Mary Ann Smale
Holly and Jeff Webb