Hello, I am writing to…

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019-0016

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31488

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Hello,

I am writing to express my opposition to Bill 108, specifically the proposed changes to the Endangered Species Act (ESA). I have been working in Ontario as an Ecologist for the past six years, and so I have first hand knowledge of how the ESA works. I agree there are aspects of the ESA and its regulations that could be improved to increase efficiency, but the drastic changes currently proposed are unacceptable.

I believe it is critically important to separate industry / developers interests and the scientific assessments of Species at Risk. The Minister of Environment alone should not be able to decide, delay or change the status of a Species at Risk, or influence the level of protection.

The proposed changes also include downlisting of species that are more common south of Ontario in the US. This is a flawed argument because the northern limit of their range here in Ontario will become increasingly important for the long term survival of the species as climate change advances. These Carolinian Species at Risk are an intrinsically wonderful part of Ontario, which also attract tourism. We are experiencing a biodiversity crisis on a global scale, and we need to be a leader here in Ontario.

Finally, the changes include allowing developers to pay into a fund for species conservation efforts instead of going through a permitting process. While I believe the phrase "pay to slay" is a bit unfair, if the conservation efforts are not focused in the same region as the habitat impacts this will lead to significant population declines. There is also no specific monitoring requirements proposed for the conservation funding activities, which means we will have no idea if the measures are effectively compensating for impacts.

Please oppose Bill 108 and any changes to the ESA that will have a negative impact on Ontario’s Species at Risk.