As a biologist with…

As a biologist with experience working in both the not-for-profit and public sectors, I am concerned that the proposed legislation completely changes the intent of the current act. It significantly cuts supports for species at risk. Below are my specific concerns with the proposed changes.

Redefining Protections (removing the concept of harassment from species protections and changing the definition of habitat to remove land beyond core use sites):
Harassment leads to stress, which in turn reduces species productivity and makes them more susceptible to other harms. Preventing harassment to species, especially those classified at risk, is crucial to strong species protection. Furthermore, species do not solely use their denning sites; they typically rely on contiguous parcels of land that provide access to food, water, and protection from predators. Removing these areas from the concept of a species’ habitat would be like saying that a human solely relies on a place to sleep for their wellbeing. We know that access to healthy food and social services are crucial to our wellbeing. Similarly, access to an intact environment beyond that which is immediately used by any wild animal, and access to this space without harassment, is critical for healthy animal populations.

Reduced Duplication with Federal Legislation:
Provincial and federal species at risk legislation are not duplicates of one another. SARA focusses on species that are at risk nationally; a species may not be at risk range wide, but still be at risk locally. COSSARO helps address this, through providing protections to species that are at risk in specific habitats across Ontario. Removing protections for SARA listed migratory birds and aquatic species doesn’t cut red tape; it cuts the efficacy of species at risk legislation.

Recovery Plans and Documents and Advisory Committees:
Recovery strategies and management plans are crucial for the protection of species at risk. If there is no recovery strategy in place, and we don’t provide an avenue to understand the challenges facing a species through consultation with subject matter experts, how are we supposed to implement sound conservation measures? Furthermore, if establishing a new advisory committee is to be done in the future, then what is the benefit of removing the current committee? I am also concerned this will further lead to reduced monitoring, which prevents us from even understanding what and where species are at risk.

New Species Conservation Program and the Wind Down of the Species Conservation Action Agency:
Increased funding for voluntary activities relies on the goodwill of project proponents. These groups are motivated by their bottom line, and NOT the wellbeing of Ontarians and our environment. The role of the government is to legislate activities relating to species and environmental conservation so that project occur in a good way. This, in combination with the removal of the Species Conservation Action Agency, removes the legislated requirements for a proponent to maintain or restore habitat. While I do not support the ‘pay to slay’ principle that underlies the SCAA, it is better than not performing any species/habitat restoration associated with a project. Based on the proposed changes to existing legislation, I do not see any adequate alternatives proposed.

Registration-first Approach and Updated Compliance and Enforcement:
I am concerned that the registration-first approach will create a reduced level of oversite and will encourage proponents to cut corners in the implementation of their conservation plans. In combination with the increased funding to compliance monitoring and enforcement, I am concerned that this will lead to a reactive approach as opposed to the current, proactive one. In other words, I feel this change in legislation blatantly disregards the precautionary principle and at best, risks putting the cost of fixing poorly done habitat restoration on government down the road, or at worst, does not result in strong species protections.