I am concerned about the…

I am concerned about the changes to Ontario’s Endangered Species Act. Ontario is the most densely populated province with the highest concentration of endangered species. If there is any province that needs evidence-based decision making it would be Ontario.

1. I am deeply concerned about the proposed change that would allow developers and municipalities to pay a fee in lieu of undertaking on-the-ground protections for SAR. You state that the funds collected would be used "to fund only those activities that are reasonably likely to support the protection and recovery of prescribed species."First, the term "reasonably likely" is weak and open to too much interpretation that could cause further damage to SAR. Second, I disagree with this tactic and would argue that the best activities that are "reasonably likely" to support the protection and recovery of prescribed species at risk are to not allow further development where they currently exist and to not offer a way to pay. Allowing developers to pay a charge rather than dealing with the impacts on SAR directly will disconnect the developer from understanding the impacts of their actions on the local environment. Furthermore, it is stated that the developers would still need to consider "reasonable alternatives" for their activities, and would have to take "steps to minimize the adverse effects of the activity on SAR," but I think this language is also weak and open to too much interpretation that could effectively cause more damage to species at risk.
2. 2. I disagree with the proposed change that would "Require COSSARO to consider a species’ condition around its broader biologically relevant geographic area, inside and outside Ontario, before classifying a species as endangered or threatened." Many species at risk in southern Ontario are at the northern limits of their ranges which can extend into the United States. The northern populations of SAR in Ontario, and habitat for species at risk in Ontario are important for future adaptation to climate change for the species at risk in all of its range.
3. I disagree with the proposed change to the ESA that would "De-couple the listing process from automatic protections" and grant the minister more discretion to suspend protections for species for up to three years if the prohibitions would have social or economic impacts. Placing concern for economy over the environment is one of the main reasons why there are species at risk of extinction in the first place, so putting the ability of the Minister to suspend protections for economic concerns is counter intuitive and will undermine species protections in Ontario. Automatic protection is the best way to protect species at risk.
4. I am concerned about broadening the membership of COSSARO to those who have "community knowledge." This is a vague term that needs to be further defined because it is too open to interpretation and could open up COSSARO to people that have a different agenda or don't have adequate conservation knowledge to make informed decisions. COSSARO needs to be upheld as an expert panel of scientists that understand how to scientifically assess species at risk.
5. I disagree with the proposed change that would remove the requirement of the Minister to consult with an independent expert in the regulatory and permitting process.
6. I am concerned about the proposed changes that would allow the Minister to delay the nine-month Government Response Statement and to "extend timelines for conducting the review of progress towards protection and recovery based on individual species’ needs." The UN just released a major report stating that over 1 million species are at risk of imminent extinction. We need swift action to protect Ontario's biodiversity, not more delays.