I am highly concerned about…

ERO number

025-0380

Comment ID

148841

Commenting on behalf of

Individual

Comment status

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Comment

I am highly concerned about the proposed interim changes to the Endangered Species Act, 2007 and the proposal for the Species Conservation Act.

I am worried that these proposed changes will greatly reduce species protection in Ontario, undermine Indigenous rights, and overall harm the environment and Ontario as a whole.

The government should not have the ability to remove protected species from the list of species at risk in Ontario (SARO) at its discretion. This list is science-backed and factual. SARO lists numerous species whose population statuses range from special concern, threatened, endangered, extirpated, and extinct. These categories are assigned to species based on a scientific and systematic approach which includes both diligent research and experts of the field. Removing species from this list will not aid in their protection, instead it will greatly harm them. It is worthwhile to point out that many of these species are also considered at risk both nationally and globally. As such, it would be a national and global disservice for Ontario to abandon these protections.

I am also highly concerned about the proposal to alter the definition of "habitat". The proposal to limit the legal "habitat" of a species to its immediate surroundings is nonsensical and non-scientific. Much like us humans, plants and animals require much more than the bare minimum to survive. A habitat is essentially an ecosystem - a complex tapestry of both living and non-living factors that dictate which species can survive and thrive. An ecosystem has many factors and many interactions between species that are critical to survival. By reducing the legal capacity (and protection) of a habitat, the government will directly interfere with an ecosystem's actual ability to function.

In addition, I am worried that Indigenous communities will not be sufficiently consulted in this proposal, or the future resource extraction activities that will likely follow. The Duty to Consult is a constitutional necessity and requires the government to consult and accommodate Indigenous groups when it considers conduct that might adversely impact potential or established Aboriginal or treaty rights. The Duty to Consult is derived from Section 35 of Canada's Constitution Act, 1892, which recognizes and affirms Aboriginal and treaty rights. There are many Indigenous communities in Ontario, both First Nations and Metis Peoples. Many of these communities reside in the north, where I believe resource extraction is planned. These lands are treaty lands and Indigenous lands, and I sincerely hope that the government will honour treaty and Aboriginal rights and engage in meaningful consultation. Furthermore, many Indigenous communities hold intimate ties to the land, and especially with plants and animals. Limiting protections for species at risk may have a direct impact on Indigenous peoples' ability to exercise Aboriginal or treaty rights.

I believe these changes will not only harm the environment and Indigenous communities but will also deprive future generations of Ontario of the natural beauty this province has to offer. The government should not be stripping environmental protections but rather should be strengthening its commitments to the environment. Environmental protections are critical to building resilient communities in Ontario. We need truly sustainable action that considers the environment and social stability, in addition to the economy. We must invest in the environment in order to invest in the future of Ontario.