I am firmly against this…

I am firmly against this proposed bill, particularly with respects to the proposed amendments to the ESA and its subsequent repeal and replacement by the erroneously named "Species Conservation Act". The ESA, in its current form, is already inadequate to deal with the challenges faced by Ontario's native species in a rapidly changing world. To further water down the ESA in its current form, only to then replace it with an even worse piece of legislation is grotesque.

Firstly, the proposed redefinition of the term 'habitat' is completely inappropriate and is not a reasonable definition by any stretch of the imagination. Seasonal dwelling places used for hibernation, nesting, and other processes are incredibly important and necessary for survival, however, so are connective corridors allowing animals to travel between these sites, as well as undisturbed habitat and natural features surrounding these sites. To redefine 'habitat' to only apply to a narrow area of seasonal dwelling places ignores the basic ecology of affected species, and fails to account for the likely direct and indirect impacts of disturbance. To put this in human terms, it would be akin to bulldozing roads, playgrounds, schools, grocery stores, and nearly every piece of infrastructure outside of a person's residence and local hospital and saying "What's the issue? You can still live in your home".

I am also concerned with the removal of every section of the ESA regarding species recovery strategies, management plans, government response statements, progress reviews, and stewardship agreements. Ontario’s species, particularly those designated as at-risk, cannot withstand the threats posed by the climate crisis and habitat loss without the strategic and targeted measures outlined in these processes. I am also concerned with the small but significant replacement of the term “species recovery” with “species conservation” throughout the pertinent documents. This reads as the government being willing to sit back while native wildlife slowly but surely disappears from the wild as at-risk populations will require RECOVERY strategies to increase their numbers in efforts for populations to eventually become viable without intervention. Before we get to that point, we cannot simply prioritize conservation strategies, but must actively implement them in tandem with recovery strategies. These documents are developed by expert guidance and outline the best practices to recover populations of at-risk species. It is wholly inappropriate to remove these documents and to change the scope of environmental safeguards to ignore the importance of species recovery.

Lastly, the proposal to have Special Economic Zones exempt from environmental protections and regulations will result in a dearth of knowledge regarding the ecological community of these zones. In many instances, the modest surveys conducted for environmental impact assessments are the only source of background information for the community composition of an area. Without proper surveys being mandated, we cannot quantify the direct and indirect impacts of development on the environment. While I critique environmental impact assessments as being little more than a box-ticking exercise in practice, foregoing this process can have devastating results if reasonable mitigation measures are not considered pre-development.

As a biologist, this bill sends shivers down my spine. It is a death sentence for Ontario's at-risk wildlife species which have called this land home for time immemorial. Ironically, this proposed bill aims to “prohibit engaging in activities likely to result in a species no longer living in the wild in Ontario”. From my estimation, the very passage of this bill would likely result in the extirpation of native wildlife.