I am very concerned about…

I am very concerned about the proposed changes to protection of Species at Risk in Ontario. I am very familiar with the current Endangered Species Act, as I work with clients to address Species at Risk on their properties, obtaining permits when necessary to avoid harm to SAR, while still allowing proposals to move forward. The description of the proposed changes appear full of euphemisms; it sounds good, but many changes are proposed that will cause an overall harm and decline to SAR in Ontario. The other changes the Ontario government under Doug Ford brought forward during the last several years are an indication that the proposed changes to SAR legislation will do less to protect wildlife in Ontario.

Yes, the current process is cumbersome, but that is because the Ministry of Environment, Conservation and Parks does not have sufficient staff to review permit applications. When the process was under the jurisdiction of the Ministry of Natural Resources, many more staff were available to review permit applications, provide advice, and also sign off on permits. The fact that the Minister of the MECP must sign each permit is an administratively slow process.

The problem with the inefficiency of the ESA is not the legislation, but the way the Province of Ontario is administering it.

I am concerned by the proposed revised definition of habitat, which focusses on core areas. Wildlife rely on a variety of habitats for numerous life stages and processes, which are all critical to their survival. Linkages between these various habitats must be protected as well, to ensure wildlife can reach each habitat. The linkages must be sufficient in width and contain appropriate habitat to ensure they function well.

I am also concerned that the word "harass" is being deleted from species protections. If species are harassed, they will be negatively impacted through either direct death or having to leave the area and find new areas to live. This could be a delayed process and one that is not addressed through the proposed Species Conservation Act.

I am very concerned that although the role of COSSARO is being maintained, the government would "have discretion to remove protected species from the list". Time and again, this provincial government under Doug Ford has not listened to the advice of experts or their own advisement groups or consultants, and gone ahead with decisions contrary to the advice of experts (e.g. Hwy 413; Science Centre). I am very concerned that this government will not take COSSARO's advisement, but down-list or delist SAR when it becomes too cumbersome to deal with a species, or a species stands in the way of "building more homes faster".

I request that the current ESA be maintained. To ensure the ESA is administered appropriately and efficiently, the MECP should retain sufficient experts on staff to review permit applications. In the past, it was the District Manager of the MNR that would sign off on permits, and a similar process is suggested now.