I am commenting to express…

I am commenting to express my opposition to the proposed interim changes to the ESA, intended repeal of the ESA and proposed Species Conservation Act (SCA).

I do not believe the SCA will result in any reasonable benefits for species protection and conservation, and feel that it will actually do the opposite, and result in the overall loss of habitat and declines in species populations. I have many concerns, but due to limited time to review, I will note the following:

An act focused on protecting species and its habitats should not have to take into account social and economic considerations, as land use planning legislation already emphasizes that over species conservation; this is why we have declining populations across the Province and beyond.

The addition and removal of species to a protected species list should use a science based approach with defined criteria that can be repeatable and is transparent and should not be at the discretion of government officials and who have no clear expertise in ecology and have clear biases.

The proposed definition of habitat is very limited, and will not allow for the protection of a species. Instead of rewriting the definition, perhaps provide some technical documents to advise on interpretation of the ESA definition of habitat, similar to the Oak Ridges Moraine Technical Paper Series.

While permits may need to be streamlined, I do not believe the answer is in self-registration. From the current reading of the bill, it sounds like a proponent can register an impact, the minister sends a confirmation letter, and the proponent can move forward with the impact. How are species protected in this manner? There needs to be a transparent way to monitor, measure and ensure that impacts to habitat are avoided, mitigated, restored and at the very last resort compensated for.

Currently it appears the province will provide $20million dollars towards a conservation fund. What happened to the money gathered in the fund set up a few years ago, how was this spent and what measurable outcomes did it result in for species at risk and their habitats? This new fund sounds like it is using public tax-payers money to offset developers destroying species at risk habitat. Also – with this type of fund – how do you ensure habitat is being created or restored in areas where the losses/impacts occurred? If the fund is used anywhere in the province, and not where the losses occurred, it could result in localized extirpation of species.

In closing, I want to emphasize my opposition and sincere concern related to this proposal, and the clear abuse of tax payers money to pay for something that should be the responsibility of proponents/developers.

I understand you have a mandate to streamline the process to build homes and cut red tape, but it should not be at the expense of our biodiversity that is already facing many stressors and threats. The economic benefits of a resilient biodiversity need to be considered.