Like too many legislative…

ERO number

025-0380

Comment ID

130312

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Like too many legislative proposals, Bill 5 proposes multiple changes across many acts, making it exceedingly hard to understand the implications. That alone is not good practice, but there are two specific serious concerns, which I was able to see in the proposed “Species Conservation Act”.

First the definition paragraph 2(1) and (2) of “Habitat” is too narrow. By limiting the definition to the specific location of a species, important pathways that sustain them (water, migration routes, wildlife corridors) are excluded. Additionally, excluding former habitat precludes reintroduction of species. While the legislation creates this narrower definition, at the same time it promises not to derogate from Aboriginal Rights and Title; Rights which may include harvesting species dependent on those pathways or opportunities to be reintroduced. To me, this sets up an inherent contradiction; it’s not good policy or law.

Second, the language in the Purposes paragraph 1(b) that protection and conservation of species takes a back seat to “social and economic considerations” seems very wrong-headed. It creates the scenario where environment is subservient priorities determined by the government of the day, special interest priorities or by transitory circumstances. We must not default to short-term thinking that does not consider the more enlightened multi-generational picture.

We all acknowledge the current challenge of an antagonistic White House administration. Our governments must respond appropriately, but “appropriately” means strengthening those things that make Ontario and Canada unique and healthy, but especially those which protect our children’s and grandchildren’s future. Protection and fostering of our natural environment is one of the most important antidotes we should be pursuing because of the health, social and economic benefits it provides. This legislation seems to do the opposite.

Removing “red tape” and grooming the trail for development should never “Trump” things that sustain our communities’ health and well-being. They include the natural and cultural environments. Developers of - for example, housing and resources - are sophisticated; they have the capacity to work within rules that protect those things.

Bill 5 should be broken down to enable meaningful public review of its components and be amended to ensure that protection of the Environment and Aboriginal Rights and Title are given priority in decision-making.