The proposed changes to the…

The proposed changes to the protections for Species At Risk in Ontario would, if enacted, result in great harm to Ontario’s already dwindling populations of native plants and animals. The harmful effects will be most pronounced in Ecoregion 7E, the Carolinian Zone of Ontario. The Carolinian Zone is the southernmost part of Ontario along the shores of Lakes Erie and western Lake Ontario. The Carolinian Zone covers just 23,000 square kilometers of Ontario's total land area of 1,076,395 square kilometers.
This small area (just 2.1% of Ontario’s land area) is the most species diverse region not only of Ontario, but of Canada. There are approximately 3300 species of vascular plants in Ontario, and 2545 of these species (OVER 77%) live in the tiny Carolinian Zone. Not enough of this land is protected as wildlife habitat. As a result, the Carolinian Zone has the highest concentration of Species At Risk both in Ontario and in Canada.
Despite being just 2.1% of Ontario’s land area, the Carolinian Zone is also home to more than 60% of Ontario’s human population. This area is also home to the majority of Ontario’s most productive farmland. To protect both Species At Risk and agricultural productivity in Ontario, sustainable land use planning is needed to balance ecological integrity with “development”. Sustainable land use planning has not been seen in Ontario in the last seven years, and the proposed changes will only make a bad situation much worse.
Ontario’s wildlife needs protection not just of “habitually occupied dwelling spaces” but also protection of the ecosystems that support the species (and that the species also support). Protecting these ecosystems is important not only for the species that inhabit them, but also to maintain the ecosystem services that are critical for everyone (including humans). If we fail tom protect enough of these ecosystems to provide clean air and water, reducing flooding, etc., then we will all suffer the consequences.
Protection of only “habitually occupied dwelling spaces” or “critical root zone surrounding a member of the species” or “an area on which any member of the species directly depends to carry out its life processes” is grossly inadequate and if implemented the proposed rules will doom our children to live in a greatly impoverished world.
Consider what this proposal: (that protection only applies to) “a dwelling place, such as a den, nest, or similar place, occupied or habitually occupied by one or more members of a species for the purposes of breeding, rearing, staging, wintering, or hibernating” would mean in practice. There is considerably more to living than these five gerunds (breeding, rearing, staging, wintering, or hibernating) cover. Other aspects of life that apply to animals include feeding and migrating. Hiding also comes to mind, particularly since the proposal is to legalize “harassing” wildlife. And since harassing is to be legal, how is one to gauge what the threshold of “occupied or habitually occupied” is? If I harass a flying squirrel by yanking it out of its tree and throwing it across the road, is the “unoccupied” tree free game for a chainsaw?
In order for animals to successfully breed and rear young, it is necessary for the parent to collect food for them. Enough of the ecosystems that these animals live in needs to be protected to provide the food that is needed. Feeding areas must also be protected.
Many species of animals migrate. This means that there are places they occupy during migration that are important to their survival. If they pass through a woodlot on migration, will it be counted as “habitually occupied”? What if changing weather patterns mean the route taken varies year to year? Is that habitat protected?
For plants: Only the “critical root zone surrounding a member of the species” is to be protected. For annual plant species (that overwinter as seeds) does that mean they receive no protection at all? If the Ecoconsultant surveys a site in the winter, how does he know the extent of the “critical root zone” of perennial plant species? For trees, what is the definition of the extent of the “critical root zone”? If you pave all around the perimeter of the CRZ, leaving the tree in a sea of asphalt, where is the tree going to reproduce? For many of these species of native plant, their survival depends on being able to increase their numbers. How can this happen if only the CRZs of the last few are protected?
While the human population of Ontario continues to increase, the numbers of many species of Ontario’s wildlife continue to decline. The proposed rules will only make matters worse. Instead, please strengthen Ontario’s commitment to protecting species at risk and their habitats. A healthy natural environment is essential to the long-term well-being of all Ontarians.