Save Lake Erie's Fowler Toads

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Originally Posted: 27 December 2011

Save Lake Erie's Fowler Toads

[Ed. Note for November 2012: Last December 2011, over 700 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 reign 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. What Save the Frogs needs now, is your donation to fight this!]

FROM Save the Frogs


Tell Ontario's Ministry of Natural Resources and Fort Erie's Mayor Doug Martin to deny the required building permits for a 12-story condominium and shopping complex that will destroy Fowler Toad habitat! SAVE THE TOADS

Sign an online petition:

And/or better yet, make direct contact:

Ontario's Ministry of Natural Resources
300 Water Street
P.O. Box 7000
Peterborough ON K9J 8M5
web contact form:

Mayor Doug Martin
phone (905) 871-1600
32 Highland Avenue
Fort Erie, Ontario Canada L2A 2X5


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 (, 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 for more information on the threats amphibians face and the importance of protecting remaining amphibian populations.

Thank you for your consideration.


Thank you for everything you do for animals!