Broadly, this appears to…

Broadly, this appears to completely gut our provincial species at risk legislation, does not recognise the diversity of habitat animals and plants need in favour of an extremely narrow and restricted one, and will make it much easier for land development to occur in environmentally sensitive areas.

Specifically I am very disappointing to see “harassment of species will not be an activity that requires registration or a permit”. I do not see how this produces a net benefit. With the Ontario government promoting a One Health approach to human, animal and environmental health, protection for the environment means protection for humans and animals and maintaining healthy ecosystems with broad biodiversity is the best defense against new and emerging disease threats and spillover of diseases from wildlife to domestic animals. While reducing redundancy of federal obligations is helpful, I think the majority of this redesign is not designed to benefit Ontario in the long term.

This proposal is clear in its intention: not to protect species at risk, but to gut species protections to expedite development. Going forward with these non-scientific changes will not only be detrimental for species at risk and Ontario’s ecosystems, but also for Ontario residents and our economy, as habitat destruction impacts natural disaster mitigation, food production, clean water access, and recreation/tourism. It would be a huge mistake – economically, environmentally, and in the interest of the public, to proceed with this proposal.

I am particularly concerned about the following:

- “The government would also have discretion to remove protected species from the list”. The purpose of COSSARO is to have an “independent science-based committee responsible for assessing and classifying species in Ontario”. If the government has the ability to remove species from the list at will, then COSSARO’s purpose becomes useless and decisions will be politically driven rather than science driven. This may cause irreparable harm to Ontario’s species at risk and ecosystems.
- “We are proposing to remove the concept of “harass” from species protections”. It cannot be claimed that the proposal will “focus on the core protections essential to the conservation of species” when it is well understood by wildlife biologists that “harassment” impacts the survival of said species. It is concerning that no scientific reason was provided to remove this concept, and can only be explained as another way to reduce barriers to development at the expense of species protection.
- “The definition of habitat is proposed to be reframed” to a dwelling space – again, this change is not based on science. To scope a habitat to a dwelling space ignores all the other spaces an animal needs to survive, most notably feeding areas. If there is confusion regarding the current definition, then it should be expanded upon and clarified, not simplified to remove critical components of a habitat.
- “remove the requirements to develop recovery strategies and management plans, government response statements, and reviews of progress” – these documents are integral to keeping the government accountable in facilitating recovery of species at risk. Removing this requirement create a lack of transparency and removes government accountability for species recovery.
- Establish a new Species Conservation Program, which would improve upon and replace the Species at Risk Stewardship Program” – it is not clear based on the proposal how these two programs will differ, and where the substantial difference in funds come from (SARSP being a $4.5 million fund). Greater clarity on the new program and the purpose of the change would be beneficial.
- “Registration-first Approach” – allowing proponents to start projects as soon as they register, before a permit is reviewed and approved, will allow them to legally conduct activities in contravention of the permit, as long as the activities were done before the permit is issued. This will result in further harm to species at risk in this “act now, get permission later” approach.
- Other actions, such as removing the SAR program advisory committee, removing the SAR conservation fund, and removing protections for federally protected species also all serve to reduce protections for species at risk at a time when our environment is in greater need of protection than ever.

Without a healthy and thriving environment, we also cannot be healthy and thriving. Any short-term development or economic gains from this legislation will be minor in comparison to the long-term negative implications, which include eroding science-based and impartial decision-making, gutting existing species at risk protections without justifiable alternatives, causing long-term economic impacts from environmental degradation in an already-strained system, and potentially damaging reconciliation efforts by undermining Indigenous ecological knowledge systems and approaches. I strongly urge MECP to abandon this proposal.