Rough Agalinis

							March 9th, 2007

Greg Thomson
Director, Species at Risk
Canadian Wildlife Service
Environment Canada
Ottawa, Ontario
K1A 0H3

Re: Consultation on Amending the List of Species under the Species at Risk Act: Terrestrial
Species – December 2006

Dear Mr. Thomson,

Sierra Club of Canada is submitting this response to support the addition of the Rough Agalinis
(Agalinis aspera) to list of wildlife species at risk under the Species at Risk Act (SARA), with the status
of endangered. The public interest is served when the listing of species under SARA is decided
exclusively on the basis of science, without political interference. For this reason we support the
recommendations of the Committee on the Status of Wildlife in Canada (COSEWIC).

According to the COSEWIC Status Report, the Rough Agalinis is a herbaceous annual having a
restricted geographical range and occupying small prairie remnants mainly along roadsides in
southern Manitoba. The few small populations are at risk from such impacts as late season mowing,
burning, overgrazing and road expansion.
The Canadian range is limited to five rural municipalities in southern Manitoba. The population size
was very small in 2004: only 209 – 229 plants were found at 11 sites within an area of occupancy of
less than 5 km2.

This is a prairie species found in low wet meadows that are often at risk due to drainage or heavy
grazing. The plants occur where vegetation is sparse and the soil is alkaline. The Canadian sites
represent remnant prairie habitats found primarily along roadsides. In Manitoba, human impact
poses the greatest threat to these populations because most of them are in road allowance areas. Any
major disturbance of the road allowance undertaken for road expansion, road straightening, etc.,
would put these populations at risk. The Rough Agalinis’ habitat has been greatly reduced by the
expansion of agriculture activity and other related human activity. Addition of this species to the
SARA list would be an important first step in its conservation.

Furthermore, SARA is a legislative tool created to implement the Canadian Biodiversity Strategy,
which recognizes that “biodiversity supports human societies ecologically, economically, culturally
and spiritually.” While the listing of this species under SARA may potentially entail some short-term
impact on some activities that compete with the preservation of habitat, we stress that in following
with the goals of the Canadian Biodiversity Strategy and the scientific assessment conducted by

                                 412-1 Nicholas Street, Ottawa ON K1N 7B7
          Tel: (613) 241-4611 Fax: (613) 241-2292 email: info@sierraclub.ca web: www.sierraclub.ca
COSEWIC, the Rough Agalinis must be added to the SARA list as a step towards its protection and
ultimate recovery. The largely unchallenged prioritization of socio-economic concerns over the
preservation of biodiversity and ecological integrity has led to a crisis of extinction on a national and
global scale. Despite the adoption of the UN Convention on Biological Diversity in 1992, we
continue to face an extinction crisis both nationally and globally, thus the urgency of protecting
species at risk is increasing.

Canada has prided itself on being a country at the forefront of conservation action. As Canada’s
species and ecosystems are continually threatened by development we must reaffirm our
commitment to the preservation of the environment and the protection of species at risk. Adding
the Rough Agalinis to the SARA list is one step that can be taken towards such conservation efforts.
Failure to do so will potentially result in the loss of this species, the continued destruction of habitat,
and furthermore a step backwards in Canada’s conservation efforts.

We therefore recommend that the Minister of the Environment list the Rough Agalinis (Agalinis
aspera) as endangered under SARA in accordance with the COSEWIC status report released by the
scientific community. Please feel free to contact us should you have any questions concerning this
submission.



Sincerely,




Jean Langlois, M.Sc.
National Campaigns Director




                                    412-1 Nicholas Street, Ottawa ON K1N 7B7
             Tel: (613) 241-4611 Fax: (613) 241-2292 email: info@sierraclub.ca web: www.sierraclub.ca