This comment is to express…

This comment is to express my deepest opposition to the changes proposed under ERO number 025-0380: the amendments to the existing Endangered Species Act (ESA) outlined in Schedule 2 of the proposed Bill 5, and the repeal of the ESA and enactment of the Species Conservation Act outlined in Schedule 10.

At the height of its implementation, Ontario's Endangered Species Act was the most focused and robust piece of conservation legislation in our country. It not only actively prevented the extinction of over 230 listed plant and animal species, but safeguarded the valuable natural spaces they exist in.

The proposed removal of "harassment" protections, along with the redefining of "habitat" for listed species under Schedules 2 and 10 are, quite frankly, a mockery of any attempt at serious conservation. To protect an at-risk animal's dwelling place and the few metres surrounding it, a plant's critical root zone, or the tree on which a lichen grows, while opening the entire surrounding area to disturbance is, in human terms, the equivalent of protecting a person and their family's house, perhaps their front and backyard, and then putting their street, the nearest grocery stores, their workplace, and the rest of their city up for demolition.

The status of our species is a direct reflection of the health of our natural spaces. The Endangered Species Act was not put into place simply to protect individual, isolated organisms – protecting species means protecting ecosystems. Protecting ecosystems means protecting species.

The healthy forests, waters, and wetlands that this province's species at risk rely on sustain all Ontarians. The economic value of the ecosystem services in Ontario has been estimated to be at least tens of billions of dollars per year. Flood protection, air and water filtration, temperature stabilization, and countless more critical services are performed without cost, simply by allowing these natural spaces to exist apart from any developments or resources that may come from them. Once they are degraded and destroyed, these systems take decades, centuries, or millennia to be recovered, if they even can be.

Alongside this, the proposed shift from permitting to a registration-first system will simply make it easier for proponents to skirt any level of species protections. By allowing developers to begin activity the moment they self-register, those acting without concern for existing habitat protection will be given a fast track towards the damage and destruction of critical habitat. Damage will already have been done even after the subsequent enforcement or penalty which may or may not follow from an already weakened regulatory system. To this end, registration-first will in no way reduce the number of ESA violations already occurring but will simply result in more of them.

Finally, the government's proposals to maintain COSSARO but at the same time allow itself to remove protected species listings, remove the requirement to develop recovery strategies, remove the SAR program advisory committee, and begin allocating conservation resources only as it sees fit, comes off as a blatant disregard for science-led process. In order to make any degree of informed decision with regard to conservation, the government must work alongside and in accordance with expert advice. In the end, conservation on an "as needed" basis will only last as long as the current government feels it is worth the resources to do so. That these changes have even been proposed indicates it already does not.

The proposed weakening and repeal of critical environmental protections such as our ESA, alongside the increasing environmental recklessness of development practices, is the most recent and extreme in a series of similar actions from this government. These might result in short-term economic gain, only to push hundreds of billions of dollars in unseen costs onto future generations of Ontarians. These will be costs to public health, infrastructure, and communities, and losses to our natural heritage that will never be recovered.

I urge this government:

Do not enact the proposed amendments to the existing Endangered Species Act, nor replace it with the proposed Species Conservation Act.

Restrengthen the existing Endangered Species Act.

Commit to development that is actually sustainable, responsible, puts the well-being of all Ontarians over profit, and does not sacrifice the natural heritage that our people have always been proud to live in.

Thank you.