We are presently losing more…

We are presently losing more species now than ever before.

To suggest the present ESA is unbalanced in favour of SAR is a fallacy – our SAR need more help now than ever, not less.

The registration approach which allows proponents to “begin an activity immediately after registering” “instead of waiting for the ministry to approve permits” is abhorrent. For many sensitive areas, the professional recommendation is do not disturb – this cannot be met if proponents are able to begin activities after an online “fast and easy registration” without critical consultations from environmental professionals.

Further, science-based assessments by COSSARO are of little value if they are subject to being overridden by the government’s whim. Non-professionals have no business counteracting the conservation directives of trained scientists by removing protection benefits for SAR they know little about.

The proposed definition of habitat for animal species completely excludes survival and reserves the term for breeding or temporary stays – thus rendering habitat used for survival (e.g. to access food resources) as not habitat. This new definition does not provide clarity but rather introduces ambiguity such as “the area immediately surrounding a dwelling place described above that is essential for the purposes mentioned” specifically designed to sound as though habitat conservation is being supported whilst minimizing protected area.

The proposal states activities harmful to species can only proceed if they are registered, and recall, “proponents will be able to begin an activity immediately after registering”. So, in sum, anyone is allowed to harm species at risk as long as they register the damage they are causing.

The proposal further suggests permits to commodify SAR in Ontario, remove the Species at Risk Program Advisory Committee and rebuke the ability to establish an advisory committee. It offers only vague assurance of enforcement of the lax protection standards it requires and importantly, “harassment of species will not be an activity that requires registration or a permit”.

This proposal completely undermines science and the professionals that have dedicated their lives to species protection in favour of unchecked development – it cannot be accepted.