Hello, I am a biologist that…

Hello, I am an Ontario biologist that works with an Endangered species. I have worked in conservation for a decade, and I believe this proposal directly threatens Species at Risk in Ontario. This proposal suggests that current systems of regulation be dismantled with no guidance on how agencies are to proceed, leaving the burden of care and conservation in the hands of developers. In my experience, this situation results in little to no conservation or species benefits. Many of Ontario's Endangered species have highly isolated populations that have small areas where they can survive. These species are all threatened by development. Salamanders and turtles in particular can be extirpated through road mortality because of their annual migrations. It is essential that regulatory processes remain in place so that there is consideration of Species at Risk when planning new development. There is still a lot to learn about our Canadian Species at Risk, and I'd argue that all populations are worth preserving, but unregulated development in southern Ontario could easily remove these species from the landscape entirely.

I am also concerned about the proposal to stop publication of Recovery Strategies and other conservation documents. As an Endangered Species biologist, I can say that these are invaluable for guiding the successful management of Species at Risk and achieving conservation successes. Reducing or eliminating the publication of these documents would be a huge setback for wildlife conservation in Ontario.

I would also like to raise concerns about whether this proposal is even legally viable. The ESA and Species at Risk Act are federal, so it seems impossible that Ontario, as a province, should be allowed to modify or ignore these federal Acts.

Overall, I think this proposal is an overt attempt to bypass regulation for the benefit of developers and construction, with little to no regard for species conservation. In particular, the allowance of anyone to start performing activities before any review is concerning, because this means critical habitats or populations could be irreparably destroyed before any regulatory authority has a chance to intervene. In regards to the proposal's cited need for critical infrastructure and development, I think more efforts should be made to locate lands and properties that will not interfere with Species at Risk. Perhaps some small changes could be made to streamline the regulatory workings of MNR and MECP, but I do not think that putting the burden of care for Endangered species into the hands of developers is responsible.

I sincerely hope that this proposal is not approved, or is at least seriously modified, to keep conservation and the burden of care for Species at Risk in the hands of experts that work with them.