I am deeply concerned about…

I am deeply concerned about the proposed changes to the Endangered Species Act. The UN’s recent report on global biodiversity decline make it clear that we need to increase our efforts to protect threatened species and take this problem seriously. However, the proposed changes do just the opposite – delaying protections, allowing the Minister to ignore the science, and making it easier to conduct activities that harm threatened species. This is not the right direction and I am very disappointed with the government’s continued attack on biodiversity, the environment, and ultimately Ontarians, whose lives depend on a healthy planet. I have listed my specific concerns below:

I am opposed to extending the timeline for listing a species to 12 months. Considerable harm can be done to species in that intervening time between the COSSARO report and the listing.

I am opposed to changes that would allow the Minister to require COSSARO to reconsider species classification. If COSSARO is an independent committee of experts made up of members with expertise in scientific disciplines or Aboriginal Traditional Knowledge (as stated on the Government of Ontario’s website), then shouldn’t they be able to come to a sound conclusion regarding the species listing without interference from the Minister? Why would the Minister come to a different conclusion than COSSARO regarding the appropriate classification? It’s important that the listing is done by an independent team of experts so that politics don’t get in the way of protecting species at risk.

I am opposed to basing a species’ classification on its condition outside of Ontario. Ontario, and Southern Ontario in particular, represents the northern range limit of many species, which may be particularly important habitat for a number of species that are expected to shift their ranges northward in response to climate change. Populations found at this northern limit may be best adapted to this area and will be vital for helping those range shifts to occur. For these reasons, not protecting the species or its habitat at its northern range limit because it may be more common elsewhere in its range is not sound, science-based decision-making. It also shifts the responsibility of species protection onto other jurisdictions, when all jurisdictions should be doing their part to protect endangered species.

I support the notion that COSSARO member qualifications should include expertise in ecology, wildlife management and community knowledge. However, it appears that all members of COSSARO already have that expertise, so I’m not really sure why this is part of the changes…I am worried that ‘community knowledge’ is a veiled term will actually allow for COSSARO members that have different agendas and priorities other than protecting endangered species. In my opinion, COSSARO members should not have conflicts of interest that prevent them from making decisions based on the best interests of endangered species.

I am opposed to the change that would de-couple the listing process from automatic protections and provide greater Minister’s discretion on protections. If COSSARO has decided that a species needs to be listed, it is because COSSARO has determined that it IS THREATENED and DOES NEED PROTECTION. Allowing the minister to suspend protections for these species undermines the entire purpose of the act. A listing is not useful if it does not lead to any action. Allowing for ‘additional time’ is allowing for more opportunity for this species to decline. Furthermore, I’m a bit confused regarding the criteria that ‘the temporary suspension will not jeopardize the survival of the species in Ontario.’ If a species is listed, then that means its survival is jeopardized and that action is required to protect it, suggesting that no species should meet this criterion and therefore no suspensions on protection should occur. Furthermore, the language of these criteria is vague enough to be extremely subjective – e.g. what is a ‘broad distribution’? Plus, habitat availability is a limiting factor for most species, considering that habitat destruction and degradation is the number one cause of species decline globally (and this holds true particularly in Southern Ontario). Since habitat availability is a factor that limits the population of most endangered species, not addressing this by not requiring a habitat regulation is extremely irresponsible. I am therefore opposed to doing away with habitat regulations for all listed species.

Reducing species protections to specific geographies and ‘specific circumstances’ is just another way of saying that the protection of endangered species is going to be minimized, at a time when it is more important than ever to increase, not decrease, protection of biodiversity. I am opposed to any change that reduces species protections in this way.

In general, giving more power to the Minister and less power to an independent team of experts allows for political agendas to get in the way of endangered species protection. I do not support any changes of this kind.

I am opposed to any changes that extend the amount of time it takes to enforce species protections, prepare a Government Response Statement and ultimately act to help endangered species recover. The current act has already been criticized on the grounds that it takes too long between listing a species and real action being taken to protect the species via recovery policies. Allowing the minister to further extend the timeline for the Government Response Statement doesn’t make sense and doesn’t act to protect endangered species. Furthermore, given that there are many uncertainties regarding how to best protect endangered species, adaptive management is extremely important for successful protection and recovery. Adaptive management requires continual review of progress, and therefore extending timelines for the review of progress is not in the best interest of endangered species.

Posting under the Environmental Bill of Rights is important to ensure that the public is aware of what is going on and that they have a right to be involved and engaged. I do not support removing the reference to posting under the Environmental Bill of Rights.

I do not support changes that allow municipalities or other infrastructure developers the option to pay a charge in lieu of completing activities that would protect endangered species and their habitats. This reduces accountability and makes it easier for activities that harm endangered species to proceed.

I am opposed to changes that remove the requirement for the Minister to consult with an independent expert during the permit process. The Minister cannot possibly be an expert on all endangered species and their needs. Furthermore, the Minister may not be able to make objective decisions due to conflicts of interest. Therefore, consulting with an independent expert should be required so that the impacts on endangered species are understood, appropriate mitigation actions are undertaken, and decisions are reviewed by an objective perspective.

Overall, I feel that these changes do not improve the Endangered Species Act, but undermine its true purpose and put already threatened species at greater risk. Ontarians deserve to be able to live in a healthy environment and experiences the wonders of biodiversity. We all depend on healthy ecosystems for our basic needs. Undermining the health of ecosystems by not protecting the species they are comprised of is a poor, short-sighted decision that will not serve the needs of Ontarians. In particular, future Ontarians are depending on us to make sound decisions and will not look kindly on short-sighted decisions such as the ones you are proposing. I urge you to reconsider these changes.