1. “ Instead of completing beneficial actions for species impacted by those activities, proponents will have the option of contributing to a fund that allows a new provincial agency to pool the resources and determine how best to implement long-term, large-scale and strategic protection and recovery activities that benefit eligible species.”
My comment: Who gets to decide? How will long term success be measured? What is large scale? Assuming there is monitoring, who is responsible if Fund actions fail to produce the intended result, especially if the proponent is no longer in operation? Little is clear in the posting.
My comment: Much of this is carrying on the work of the previous government in weakening protection of species at risk which is contrary to the government’s made in Ontario Environment Plan.
2. Payment into the Fund is an alternative to the provision of overall benefit. There is no link in the amended ESA between the Fund and the provision of overall benefit, and no requirement that the benefit be proportionate to or related to the harmful impact. The amount of the benefit to be generated is to be based on a 1:1.5 ratio, so that, for example, the loss of 1 hectare of habitat requires the provision of 1.5 hectares of new habitat. The functions of the replacement habitat are not considered.
My comment: As this is an abandonment of the idea of overall benefit, what standard will be used and how will it be measured given this requires long term monitoring to determine impact? To paraphrase others, it is unlikely you can build back better.
My comment: How will this replace the function of habitat that is destroyed given little is known about how habitats function? Seems there is little if any science behind this. Add to this the fact that payments to the Fund would be pooled and may be used to benefit any Fund species, not necessarily the one that is impacted. Once the funds are in the pot, there is no direct link between the harm inflicted (the species or the degree and location of the negative impact) and the remedy provided through the Fund. There is also a strong likelihood of significant delays between the harmful activity and any restorative action.
3. There is no requirement that Fund monies be used to compensate for negative environmental or social impacts in the watersheds, municipalities or Indigenous traditional territories where the harm occurs. Some communities will see valued natural areas destroyed or degraded, possibly with no local reparation whatsoever for the loss of ecological, cultural, spiritual, recreational, aesthetic or economic values.
My comment: What happened to the importance of local control which the current government, while in Opposition, skewered the Liberals for taking away local control thru the Green Energy Act?
4. The government will initially invest in setting up the Fund, including establishing an agency with a small board and staff for administration. After the first year, MECP anticipates that the agency will be financially independent. In other words, it expects all costs to be covered by the Fund itself.
My comment: And what is plan B if the costs are not covered? I assume that the ability of the administration to function will be reduced rather than additional funding provided. Or is the intent to rob from the Species at Risk Stewardship Fund which is working just fine with government interference.
5. In administering the Fund, the agency responsible is “to publicly communicate its focus for funding, by submitting to the ministry and publishing a plan for each conservation fund species before any funds are disbursed for the species.” It will also release annual reports that document “information about funded activities.”
My comment: There is no requirement or expressed intent, however, to share with the public information about the specific or cumulative impacts of the harmful activities undertaken by proponents (e.g., where the harm occurs, what type of activity or impact, who is responsible, the total area damaged or destroyed). This missing information will make it impossible for the public to assess whether the Fund actions are commensurate with the level of habitat destruction caused by the authorized activities. Similarly, it will make it impossible for the public to track cumulative adverse impacts across the ranges of species at risk.
My comment: Lack of transparency and public accountability which is the opposite of what this government promised.
Submitted December 16, 2020 4:09 PM