I am commenting to say that…

I am commenting to say that I am firmly opposed to the proposed changes to the Endangered Species Act and other related changes under Bill 5.

The language used in the proposal is inherently biased and unbecoming of a government agency. You repeatedly note “unnecessary” delays to development, which are not unnecessary if there is to be an actual evaluation of impacts to species and their habitat. Such an evaluation requires the collection of site-specific data and an analysis of the proposed effects, and those cannot be completed in an instant. The delays are only “unnecessary” if you don’t value Species at Risk or don’t understand the complexities of ecological systems.

Regarding the proposed registration-first approach – what evidence is there that the existing registration process is “already successfully used for many species”? This approach has been pushed for use but there is little to no oversight, review, or follow-up to determine if the process actually works as intended for the protection of species. It may make sense to use this approach in certain circumstances or for certain species for which the biology and habitat are understood with easily anticipated impacts/mitigation measures, but to use this as a universal approach for every application, including large-scale development or site disturbance, is completely inappropriate. It’s trusting the future of our rare species to the honor system, with no incentive for proponents of projects to put in the necessary work to actually understand the species and habitats that their proposals are affecting or what measures are appropriate as a response, before ramming forward and breaking ground.

Regarding the changes to species classification and listing, and specifically the proposed ability of the Province to list or not list species as they see fit, regardless of the recommendations of COSSARO – granting the government the right to ignore science-based recommendations at their discretion serves no purpose except to allow the government to ignore species that are inconvenient for them. Keeping COSSARO active in this scenario is nothing more than lip service.

What is the intention of or basis for removing the concept of “harassment” from legislation? Wildlife species that are stressed by human disturbance – i.e., harassment – are less fit and less likely to survive and reproduce successfully. If your goal is to actually protect at-risk species and promote their recovery, this is not a step in the right direction.

Regarding the redefinition of “habitat” – the provided revised definition for both plant and animal species is far too limited. What about area-sensitive species that require large areas of contiguous suitable habitat in order to thrive? What about animals that have large overall territories or are known to move around a lot like Blanding’s Turtle? What about supporting habitat like feeding areas which would still be necessary to keep the species alive? The redefined terms do not allow for consideration of such nuances; in trying to create “clear terms and parameters” you’ve stripped away too much from it.

Regarding the removal of the requirement for Recovery Plans and other documents – this will only serve to remove government accountability and the requirement to actually address the listing of species in any meaningful way.

My concerns for the changes to the ESA overlap with my concern regarding the “Special Economic Zones” from the rest of Bill 5. So you are intending to make arbitrary decisions about where species protections should and shouldn’t apply, based on… what, exactly? The fact that you want to build there and don’t want to bother with environmental investigations and protections? This is an absolute travesty and should not be allowed, it does not allow for necessary investigation and consultation prior to development, and it assumes that economic desires trump every other possible consideration that could apply. This is not sustainable in any way and will harm Ontarians in the end.

You’re very focused on how the changes will make the government’s job easier and make it faster and easier for development to go forward, and not at all focused on how the actual species and their required habitats will be protected and restored. Our at-risk species are experiencing more and more pressure and need improved protection, not reduced.

You have provided no evidence that the proposed changes will benefit Ontarians or “protect Ontario” in any way. It could not be more obvious that your priorities are on the strip-mining of Ontario’s natural resources for profit, and that you have no regard whatsoever for ecological sustainability or the kind of world that our children will inherit. The proposed changes are disgusting and should not be carried forward.