When the ESA was introduced…

When the ESA was introduced it was the Gold Standard for protection, over the years it has been watered down, and these latest proposed changes would render the Act useless and push many of the species listed over the brink.

Perhaps some regulatory burden for agricultural activities needs to be lifted, but we should not be decimating the Ontario’s Endangered species for the sake of housing or industrial development, and especially not for tourism!

The proposed changes include diminishing the decision making power from COSSARO, and giving it to the Minister. Decisions should be left with the scientific experts not put in the hands of politicians who do not have expertise in the subject.

Once a species at risk is listed it and the threatened or endangered species and its habitat. The Minister should not have the power to pick and choose what species and what habitats should be protecting and when. Giving the Minister this discretion would provide too much opportunity for interference from developers and lobbyists, protection of the environment, and wildlife should not be subject to political whim and economic pressure.

ESA protections should not be limited to apply only in specific geographies or under specific circumstances. If a species of habitat is to be protected it should be protected everywhere and under all circumstances. If you must limit protections than it should be on a case by case basis, that needs to be approved by COSSARO.

COSSARO should base its assessments on the status of a species in Ontario, not on its status throughout its range. As an Ontarian I am concerned with seeing the extirpation of species from our province. If CASSARO has to base its assessment of the entire range a species we may see the disappearance of the unique species (or their habitats) from Ontario because they are not threatened in other areas of the continent. This is especially concerning in the face of climate change because healthy species populations are needed at their northern limits to help species adapt to changing climatic conditions.

The idea of allowing developers and other proponents of harmful activities to pay in lieu of fulfilling requirements for on-the-ground compensation is revolting and not something that should be considered in progressive third world country. You are providing with developers with a way out of their responsibilities as good corporate citizens. Any company that wants to do business in Ontario should understand that we are not a province that is willing destroy the wildlife, plants and habitat for the sake of business. This move would make it far too easy for proponents to move forward with harmful activities.

The proposed landscape agreements for proponents undertaking activities in multiple locations does not lend itself to addressing site-specific or species-specific concerns. Not all sites are the same and different species require different actions, the landscape agreements would present additional risk for species already at risk.

The removal of the requirement to consult with an independent expert prior to creating regulations that would jeopardize the survival of a species, or issuing permits for harmful activities is unacceptable. This proposal is putting development before the protection of our natural heritage, and ignores science. No industry should be exempt from the ESA no matter how much they contribute to Ontario’s economy.

Delaying the listing, planning and reporting on species at risk, is of deep concern and undermines species recovery. By delaying the listing of a species by 9 months puts species further at risk as within this timeframe vulnerable plant and wildlife habitats could be destroyed or irreparably damaged.
Need to post to EBR for public comment and not just to the website, the EBR is the tool for public, and other stakeholders to be notified about potential changes and make comments. Not posting decisions to the EBR is a cowardly tactic to avoid drawing public attention to political decisions that are detrimental to the survival of species that that are at risk in Ontario, and allows those with political connections the opportunity to undermine species protections without full public scrutiny.

The creation of any Species At Risk Conservation Trust should be run by a board that is elected or appointed based on skill set and expertise, not political appointments. It should be a board of scientists, not developers, lobbyists and politicians.

I do not support changes which would introduce broad ministerial discretion to interfere with the science-based listing process, to suspend and limit protections, and to ignore legislated timelines for policies and reporting. Nor do I support the “pay-to-slay” scheme that would grease the wheels of destruction by allowing developers and other proponents of harmful activities to pay into a fund in lieu of fulfilling requirements for on-the-ground reparation for the damage they do to species and their habitats.