I would like to express my…

I would like to express my opposition to Bill 108 and deep concerns about the proposed changes to the Endangered Species Act (ESA) that in my opinion can have a dangerous impact on species at risk in Ontario.

The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) report released this May 2019, drawing from 15,000 scientific and government sources and compiled by 145 authors worldwide issued that 1 million species are threatened with extinction. The report insisted that 'transformative changes' are needed to reform and protect nature.

The proposed changes to the Endangered Species Act listed in Bill 108, has the potential to do just the opposite and pose a great risk to our species at risk in Ontario. There are certainly ways to improve and make the process of protecting our species at risk more efficient, but with the bottom line of protecting our species at risk. My concerns are that the following changes will not be effective at protecting our species at risk and may actually put them in great peril.

I believe that:
1. 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. It is critically important to separate industry / developers interests and the scientific assessments of Species at Risk.

2. There should be no 'downlisting of species' that are at risk in Ontario, but more common in other geographic areas. This is truly a slippery slope. The areas where species are now common may later change. This is also a flawed argument because the northern limit of the species 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.

3. Developers should not be able to pay into allowing developers to pay into a fund for species conservation efforts instead of going through a permitting process. 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.