I am writing to strongly…

I am writing to strongly oppose the proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025. Ontario's informal slogan is "yours to discover" and this motto shows how nature is at the heart of the province's identity, as it is for all of Canada. From an economic perspective, Canada is dependent on natural resources, and those resources are dependent on healthy ecosystems and biodiversity. From a social perspective, Ontarian identity is grounded in its relationship with nature - outdoor hockey rinks, stunning provincial parks, unique wildlife, cross-country ski trails - and this is true for Indigenous peoples within Ontario even more so. Evidence shows that nature also significantly improves people's health, which reduces the strain on an already severely constrained provincial health system. Please see a summary of key issues with these proposed changes:

1) Change of approvals: Risks to the environment are often viewed as externalities in economics, so it is imperative that governments ensure protection and adequate consideration before development starts in order to counterbalance negative outcomes from economic development. This also ensures a sustainable long-term economic growth, as Ontario's industries will continue to rely on natural and nature-based resources in the future. Waiting for approvals does not slow the process down; it provides this balance to adequately reduce the environmental and long-term economic risks to the province. It slows things down for those unwilling to consider their negative impacts, which is all the more reason why risks should be considered at the outset and contracts awarded to actors willing to comply. The new changes give a disproportionate amount of power to private companies who already hold immense sway in politics. This will have the opposite intended effect on what you propose to be helping "sustainable economic growth". Companies should not get a free lunch at the public's expense nor the province's future markets.

2) Voluntary initiatives: These have proven to not be enough to incentivize action to mitigate negative environmental impacts. The value of nature globally to people has been calculated at about $125 trillion a year, yet this substantial amount is outweighed by less sustainable development approaches by politically motivated, short-term gains.

3) Habitat redefinition: This redefinition does not adequately meet scientific and Indigenous knowledge and rigour. We live in a complex, interconnected world, and such a simplistic definition will have consequences. A broader definition allows for contextual considerations.

4) From plans to guidance: The replacement of "develop[ing] recovery strategies and management plans, government response statements, and reviews of progress from legislation" with "conservation guidance" will provide few incentives for actual conservation methods to be considered and it will not hold groups accountable for harms to the environment (although this last point is less relevant when the initial protection measures as now proposed would be weak). To encourage sustainable economic growth, we must work together, not give companies carte blanche. Recovery plans and strategies require collaboration, guidance does not.

5) Advisory committees removed: Getting rid of advisory committees removes third party expert advice from scientists and others who study and understand the impacts more than governments or industry. Moreover, they have available mitigations and examples from other experiences to lessen the negative impacts and increase the positive impacts.

6) Federal role: Your argument that the option for federal intervention remains and that this change simply removes duplication is misleading. As seen with recent proposals, when the feds tried to intervene for a threatened species of frog at risk, Ontario launched a court challenge. Moreover, with recent court rulings for the Impact Assessment Act arguing that the feds overstepped into provincial authority, it is clear that these proposed amendments are to abdicate responsibility for environmental protection, not to ensure protection through elimination of duplication.

Lastly, habit loss and degradation is one of the leading causes of biodiversity loss in Canada, and biodiversity loss is intrinsically connected to climate change. As the federal government has noted, "Nature can be a powerful ally in the fight against climate change, both in terms of mitigation (reducing emissions) and adaptation (enhancing resilience to climate change impacts)." Insurance companies have been studying climate change impacts for years and know that worsening climate events will continue to severely damage homes, increase premiums for Ontarians, and that promoting climate change resilience and mitigation is key to reducing these impacts, especially in a province already in a housing crisis. Protecting nature is a crucial tool in this toolbox from flood mitigation to reducing the impacts of ice storms.

Ontario is a province for people of all ages and backgrounds to discover, but with your proposed changes, it is yours to destroy.

Respectfully