I am deeply concerned with…

I am deeply concerned with the proposed changes to the Ontario's Endangered Species Act. Ontario once had the gold standard to protect species at risk and since the Ford government obtained power, the Act has been gutted and has loss purpose. The species listed under Ontario's Endangered Species Act are the most vulnerable in the province. We must do everything we can to protect them or we risk major ecological consequences.

The major concerns I have relate to:

1. The new proposed definition for "habitat". The new definition for animal species which is: "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 the area immediately surrounding a dwelling place described above that is essential for the purposes mentioned"

This new definition does not align with the scientific description of habitat. Habitat is defined as area that is required for a species to survive. Breeding, rearing, staging, wintering, or hibernating is an important part of a species habitat, but what about the area it needs to forage ? Can a human live in its bed solely and survive ? No. So why would we be restricting animals to that definition. If you are not protecting all critical habitat for species at risk then you are increasing their vulnerability to threats. This proposed change is counterproductive to the objective of the Endangered Species Act itself.

2. Streamlining permits through the registration first approach. All development projects should be carefully considered for their environmental impact including their impacts on species-at-risk because once damages are done to the environment, these damages generally cannot be fully repaired. It is in the best interests for Ontarians to have a healthy environment as the health of the environment is intrinsically linked to their health as well.

3. Removing protection from aquatic species and bird species that fall under the federal Species at Risk Act (SARA). The provincial and federal Act have different scopes. Species listed under the federal Species at Risk Act are only protected on federal lands. The Ontario Endangered Species Act protects species listed under the provincial act on private and public lands, therefore ensuring the species are protected across the province and not only on federal lands. By removing the protection from these species, you are greatly reducing policy to protect them, which is counterintuitive to the Act itself.

4. Removal of the recovery strategy. Recovery strategies identify major recommendation that ensure best practices and efficiency when it comes to recovering species at risk in the province. Without these documents, a clear plan to recover the species at risk is not in place. This is inefficient and could lead to ineffective and wasteful expenditures to help conserve the remaining populations of species at risk. If we do not have a clear plan in place, how do we know how best to protect the species and ensure they are still here for the next generation ? This proposed change could have economic implications.

5. Harassing species-at-risk is allowable. One of the proposed changes in the new Act is that the harassment of species-at-risk would be allowable. Harassing species-at-risk, which by definition, directly affects their survival, would have considerable consequences. This again, is counterproductive to the purpose of protecting species-at-risk. Harassing can lead to further decline in population sizes, which can lead to extirpation of that species in the province. Harassing species-at-risk should absolutely not be allowed in Ontario.

As of presently, the status of our species-at-risk in Ontario is generally not improving. So why would we reduce protections rather than implement more caution to reach the purpose of the Act itself. No money in the world can return a natural environment to what it previously was before it was destroyed or fill in the niche of a species that has been lost from an ecosystem forever. The proposed changes will reduce protections for species at risk which can lead to, in most severe cases, complete ecosystem collapse. Each one of these species-at-risk has a role and responsibility in their ecosystem. You are threatening their roles within the system, which threatens the delicate balance of the environment. Imagine the ecosystem as our human society. If all, for example, postman or police or doctors were to be removed from our society, our society would collapse in certain aspects and there would be a vacant role that would need to be filled to ensure the proper functioning of our system. That is the same with our animals and plants. When you remove one species, you are threatening the whole system and, just as a friendly reminder, we are part of that system and we will pay the consequences as well as all other species. So what is more important ? Another strip mall or keeping our environment in balance? All native turtle species in Ontario are currently considered at risk of extinction. Turtles cycle nutrients in our environment and spread seeds – this is their role in the ecosystem. One of the excitements from my childhood in northern Ontario was to go see snapping turtles at the lake. I can’t imagine taking that experience away from my children – all in the name of rapid unsustainable development. At the rate that the Ford government is taking in terms of the environment, that very well could be in our not-so-distant future. I sincerely urge the government to reconsider the proposed changes before irreversible damages are done to Ontario’s environment.