The proposed changes to…

ERO number

013-5033

Comment ID

30835

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed changes to Ontario's Endangered Species Act largely undermine its intended purpose, at a time when we need it to strongly protect our most vulnerable biodiversity. With the May 2019 publication of the Global Assessment Report on Biodiversity and Ecosystem Services by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), we have unequivocal scientific evidence that our global biodiversity is being lost at an unprecedented rate. Weakening our ESA , for instance by allowing developers to pay into a conservation fund to be allowed to continue destroying habitat of a listed species is incredibly shortsighted and detrimental to the survival of endangered species in Ontario. Habitat for many endangered species is rare itself, and once it is gone, the conditions to allow for the survival of species that rely upon that habitat cannot be easily restored. There is no amount of restitution paid into a conservation fund that can cover the costs of restoring that habitat, and inevitably, the species that relies upon that habitat, once it is forced to become locally extinct, or worse, completely wiped off the earth.

A key element mentioned by the changes to the Act include an analysis of whether a species assessed as endangered should be considered as such based on its population elsewhere in other adjacent provinces, countries, etc. This does not take into account the adaptations of species that are at the northern limits of their range that are therefore rare and at risk in Ontario. Many species that are listed in Ontario which may be more common in other regions should not be discounted as not worth protecting - they represent evolutionary adaptations at the edge of the northern limits of their range, and may provide genetic diversity in their species that can allow for survival in the face of climate change. Additionally, if they are lost from their range in Ontario, any members of that species that move north as our climate warms, will likely have less or no habitat conditions in which they will survive, and will become further endangered.

De-coupling the listing process from automatic protections and allowing increased ministerial control, such as with the temporary suspension of listing a protected species puts the ESA on an incredibly dangerous road. Combined with the open season for developers to pay out of conducting proper protective measures, this is absolutely disastrous for any species that dare live somewhere a company wants to put another subdivision. This is not a scientific way to protect our species, and is founded on partisan politics that place big businesses ahead of the foundation of our society - the natural world we rely upon. Scientists and community members and the advice they provide through COSSARO is expertise that the minister should rely upon - not their own personal opinion of what species and habitats should be protected. By ignoring the precautionary principal, and delaying the listing of species assessed as endangered, we are risking the survival of rare, extraordinary species in Ontario, and sacrificing our identity as Ontarians, and Canadians, who see our wild spaces and species firmly linked with our culture and pride in our home. Do not sacrifice this for extra developer dollars. They are not enough.

Ontario's Endangered Species Act was once lauded as one of the most stringent and potentially effective ESAs in North America, if not the world. It does need to have some amendments, in order to allow for better communication with stakeholders to provide a stronger understanding of the parameters and process of protecting species. Action plans must also be developed and implemented more quickly, in order to actually put the ESA to work. But the amendments proposed by the current government do not achieve this goal. They aim to make our ESA a sham - a shell of legislation that has no teeth and no actual ability to protect our most vulnerable species. This is unacceptable. This is bulldozing our biodiversity, both literally and figuratively, and our province will suffer consequences that will be felt for decades, if not centuries, into our future.