I am encouraged that the…

I am encouraged that the intent seems still to ensure the ESA includes "a provincial species at risk list that is automatically updated based on classifications by an independent scientific committee". I am concerned that some the proposed changes do exactly the opposite. They will:

- Allow developers to pay into a fund to proceed with development while harming species and their habitats rather than creating a net positive benefit for affected species.

- Change the assessment criteria such that if a species is not considered endangered in another region outside Ontario, then the species would not get status in Ontario even if the species is threatened or endangered within Ontario. In fact, the large majority of the almost 200 species currently classified as threatened or endangered would not meet this criterion. Among other issues, this ignores the consideration that northern range expansion of species will likely be required as habitat further south becomes less suitable for species stressed by climate change.

- Dilute the composition of the Committee on the Status of Species at Risk in Ontario (COSSARO), the committee of scientific experts that makes decisions on the listing of endangered species, by the addition of those with a vaguely specified “local knowledge”.

- Allow the minister to remove protections for up to 3 years based on economic considerations rather than retain the current automatic exemptions. The minister would also be able to require COSSARO to re-evaluate a species for possible removal from endangered status.

- Where other legislation addresses activities involving interaction with endangered species, allow provisions under the ESA to be disregarded even if these provisions are stricter. This would permanently exempt the forestry industry under the Crown Forestry Sustainability Act and open the door for other industries under future legislation.

- Remove the requirement for the minister to consult with an independent expert on whether survival of a species would be jeopardized prior to creating a new regulation under the ESA or when issuing a permit to harm a species for economic benefit.