We are experiencing a global…

We are experiencing a global biodiversity crisis. The proposed replacement of the Endangered Species Act in Ontario is a disappointing and inappropriate action. This proposal suggests that the Provincial government does not value species at risk in Ontario. This is a transparent attempt to de-value endangered species in favour of construction projects and development. Truly sustainable economic growth involves safeguards like a robust, science-based ESA. I strongly oppose this proposal to weaken protections for species at risk in Ontario.

The government should not have discretion on what species are protected under the ESA/SCA. As an independent science-based body, COSSARO’s recommendations should be accepted by the government. When COSSARO recommends a species for protection, the government should not be allowed to reject the recommendation. Such a rejection would not be science-based decision making.

I do not agree that the registration approach is an effective means by which to conserve species at risk. Permits should still be required for any activities that contribute to the decline of SAR. This streamlined approach does not involve enough scrutiny of development projects that could be detrimental to species at risk. It places too much trust in developers to comply with the conditions of the registration.

In my opinion, the changed definition of habitat is the most detrimental proposed change. If accepted, the revised definition of habitat will not suffice to protect species at risk. The government simply cannot protect animal species by only protecting their residence sites. The new proposed definition does not reflect what we know about animal ecology. Many species require diverse habitats for different aspects of their life history such as foraging habitats, spawning/breeding habitats, and migration corridors. These habitats are necessary for organisms to carry out their lives; if they are lost because of development or other disturbances, species at risk will continue to experience population declines.

The removal of the need for to develop recovery strategies and management plans, government response statements, and reviews of progress is outrageous. These documents are needed to guide the recovery of SAR.

Permits should still be required by the provincial government for aquatic SAR and migratory bird species to safeguard their protection.

I support the continuation of Species Conservation Program and the Species Conservation Account. However, the government should prioritize conservation of existing organism populations over compensatory restoration efforts after developments/disturbance.

I support the general prohibition for activities that would result in a species no longer living in the wild in Ontario. However, a more effective conservation measure would be to prohibit any actions that would cause range contraction or population declines in any SAR.