I have read the overview of…

I have read the overview of the proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025, and am very concerned. Please read my comments below and give them your serious consideration. Please do not pass these proposed changes. Thank you.

1. Habitat restoration sounds like such a nice, simple thing… however, once the habitat of an endangered species is disturbed, once the wildness of a natural space is torn up,
“restoring” it is next to impossible. Where will the wild things go in the mean time?

2. It is irresponsible to allow for construction, mining or similar activities to start immediately upon registration. How can the government know what habitat or species are at risk in the land in question ahead of time? The government has not conducted environmental surveys in advance on every square inch of the province. There is no way that the applicants at this stage in development would have the knowledge or expertise required to identify habitat or animals which make the proposed sites their home.

3. This bill speaks of protecting animals’ dwelling places etc. “for the purposes of breeding, rearing, staging, wintering, or hibernating”. But what about space for the daily life and well-being of these animals? Where are they supposed to live when not carrying out the activities outlined above?

4. This bill doesn’t provide protection for aquatic animals! Passing this responsibility on to the Federal government is unprofessional—the Ontario government should absolutely be aware first-hand of the health of aquatic habitats and the animals that live there.

5. Migratory birds require specific terrain, plants and geological features in order to successfully navigate to and from breeding grounds. They deserve consideration and care.

6. How is it a good thing, to “remove the requirements to develop recovery strategies and management plans, government response statements, and reviews of progress from legislation.” Long-terms planning, oversight, and review of consequences are important tools needed to inform future decisions. Also, an advisory committee is essential part of managing the areas in question responsibly.

7. The bill says “Ontario remains committed to species conservation and to promoting activities like habitat restoration...” If vulnerable habitat is CONSERVED in the first place, the expense of restoration would not be required.

8. I find it disturbing to think that “the government will have discretion to add species to or remove from the Species at Risk in Ontario (SARO) List.” Under what guidance, seeing as there will no longer be an advisory committee?

9. The use of the word “harass” is appropriate in many circumstances, and removing this language from such legislation means that the physical and mental well-being of animals is being disregarded. Also, certain necessary habitats in Ontario shelter rare plants as well as animals, plants which will die if their roots are disturbed, plants which require very specific ecological circumstances. The harassment of species must absolutely be “an activity that requires registration or a permit”.

10. This bill doesn’t take into consideration the insect life which is reliant on what some might see as worthless land. Insect life is an essential part of the circle of life, feeding birds and fish, bats and small mammals.

11. Conservation is the key to preserving the precious little wildlife and habitat that still exists in Ontario, often in isolated pockets. Wildlife has already been cut-off from the terrain it needs to travel in order to maintain healthy populations; treating these species with such a lack of care and consideration may tip many of these over the edge to becoming unsustainable, even extirpated.

12. It is appalling to me that this bill states that “the requirement for the government to develop recovery products for species will be removed from legislation.” What is the purpose of government if not to safeguard what precious wildlife and habitat, especially in south-western Ontario which is so built up? Providing tools to aid in the recovery of species is a key responsibility of the provincial government.

13. It is disturbing to read that if this bill passes “the government will have discretion on what species are protected.” With no advisory committee, how can they possibly make these kinds of assumptions and pronouncements?