The proposed changes to the…

ERO number

025-0380

Comment ID

148952

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Individual

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Comment

The proposed changes to the Endangered Species Act (ESA) impact matters of Provincial significance, and are not a benefit to the people of Ontario.
Changes to Species at Risk (SAR) definitions of habitat reduce protections for the areas that are critical to SAR life processes. Examples of this are root zones around SAR trees such as Butternut, and foraging habitat for SAR birds. Changes to the definition of habitat will result in not only immediate harm to SAR, but long-term reductions in SAR populations as well. Federal laws are not robust enough to overcompensate for Ontario’s reductions to SAR protections.
Proposed creation of the Species Conservation Fund would bring Ontario into a pay-to-destroy model. Globally, including Ontario, biodiversity trends are crashing. Habitat is only created when there is a proponent paying for their impacts, which is barely offsetting the loss of SAR habitats happening through development processes. Examples of this are offsite creation of watercourses for Redside Dace, or changes to farming practices to support Eastern Meadowlark egg laying and rearing. Nobody is creating these habitats at scale outside of the ESA compensation obligations. The proposed Conservation fund will not create habitats compensatory to removals through development impacts. Removing the funds from direct habitat recreation, and focusing funds on research, will result in significant net losses to SAR habitats currently being mitigated through direct offsetting activities. With the trending decline in biodiversity due to primarily habitat loss, the creation of a conservation fund is counter policy to what is needed in our Province right now. Species at Risk are identified as the most precarious and vulnerable species in our ecosystems, so habitat loss and other causes of biodiversity decline impact them disproportionally worse. The ESA should be strengthened going into the future of Ontario, not weakened.