I see no evidence that the government is taking a science-based approach to the protection of Species at Risk with the proposed changes. As a voting member of the public in Ontario, I demand to see proof that better protections and actual results for recovery can be achieved via any proposed changes.
What I can see is that the government is making it more profitable to develop Species at Risk habitat without accountability on the government's behalf on if there is any expectation to achieve the stated objectives. There are far better ways to achieve economic stability than to simply allow habitat destruction with easily achievable restrictions.
Some major issues with this, besides the overarching issue noted above:
- How will the members of the board-governed agency, called the Species at Risk Conservation Trust, be appointed? what will their credentials be? Simply stating that they must have applied knowledge of, and expertise with, concepts and techniques related to the protection or recovery of species at risk is insufficient.
- There is no definition of what constitutes "a qualified person" with regards to meeting the requirements related to Butternut health assessment. This absolutely needs to be clarified, or it will be anyone who deems themselves qualified, especially as these regulations are up to proponents to follow.
- There must be government staff and funding for checking that information being provided by proponents is accurate or that they are in fact carrying out appropriate surveys. Allowing proponents to decide when they need to carry out Species at Risk Surveys without having anyone check their decisions is essentially asking the fox to guard the henhouse. This government neglect in applying oversight amounts to complicity in degradation and further damage to SAR and their habitat.
- The MECP/MNRF Enforcement Branch must be funded to be able to carry out inspections under the ESA, and have targets or protocols. Relying on complaints or tips, or referrals from operations staff who may have grounds to suspect non-compliance is not suitable in a self-regulated atmosphere. It is like asking driver's to give themselves a speeding ticket when they breach speeding laws, having no police checks, and hoping the public will call in speeders. It is entirely unrealistic to assume this approach will work.
- The proof of effectiveness of the proposed changes is not there, and would be simple enough to obtain. It lies on the government, not on the public, and determining how effective the past changes (referring to 2013 changes allowing for self-regulation) achieved protection and in fact improved recovery for species at risk. As far more species have become at risk since the implementation of the ESA than have been downlisted or delisted, there is hard evidence that it is not effective.
- While habitat for 4 of the six species proposed for easier registration processes arguably require habitat that can be constructed within a shorter time span, Eastern Whip-poor-Will requires large tracts of mature forest, which can take over 50 years to replace, and Blanding's Turtle are a slow-reproducing species that cannot afford any more losses due to human damage caused by roads and wetland destruction. You say "We anticipate that these six species will benefit from a more strategic and coordinated approach to planning and implementing large-scale protection and recovery efforts." but I see no proof, no studies to support this. First provide the proof.
Essentially, the government is allowing damage to be wrought on the environment and biodiversity, which belongs to all members of the public, to the benefit of mainly private companies, hydro power companies, and dam operators. Without the minimum of addressing the above-noted concerns, this is simply allowing private companies to externalize their costs to the general public, something that has become a Conservative Government hallmark.
I am demanding that these changes are not approved as is, and that if proof of effectiveness as stated are not given, that this is confirmed through study FIRST.
Submitted November 13, 2020 2:03 PM