To Whom it May Concern I…

To Whom it May Concern

I have concerns regarding the Proposed interim changes to the Endangered Species Act of 2007 and the proposal for the Species Conservation Act 2025. Please see below for my thoughts:

The proposed changes do not provide a balanced approach; they provide the ability for developers to wipe out natural and protected habitats to build. Without an environmental assessment, by people who are qualified to make such an assessment, how exactly are likely direct negative impact on species going to be determined? I will give the introduction of the Cane toad into Australia as an example - a well-meaning poorly thought-out approach which has been disastrous.

It's easy to say you will strengthen the ability to enforce species protection, when you have stripped species protection to a bare minimum.

I think that the idea of sustained growth is an incorrect approach, and a disastrous paradigm. Growth cannot be sustained, at some point there must be an end to it. In medicine, we call sustained growth cancer, and it kills. At some point we will run out of Earth, and it will kill us. Developers have shown time and time again they are only interested in making money, not providing affordable housing. Not everyone needs a massive home with cathedral ceilings and rooms that no one uses. In fact, one could argue that no one needs these things, but rather wants them, because we have been taught to want them. I would give Bhutan as an example, where Gross National Happiness is measured along with GDP, and while the Developed world would consider Bhutan poor, the people there are, for the most part, happy.

By allowing COSSARO to make decisions on the classification of species, you are using government to work according to its own agenda. This is a huge conflict of interest. Species designation should never come from government but rather from organizations whose sole purpose is to protect the species in question.

If we are redefining habitat for animal species, are we redefining habitat for humans as well? Thus, my habitat is only my house, and not my community. To think that a habitat is only the space occupied to breed, rear, and live in winter is to misunderstand what a habitat is. If I am only allowed to live in my house where I breed, rear my children, and winter, how will I obtain food? How will I work? How will I help others in my community. Animals are much like humans in that they have a community they live in. They need space to be able to source food, interact with other species, and do the work of survival. For vascular species – does water not come from all over, washed down (often with added road salt)? Nutrients are fed through the soil – transferred by an amazing fungal network connecting each plant to one another - I would recommend reading: Finding the Mother tree by Suzanne Simard to understand the interconnectedness of our world. We have already made it so hard for our natural environment to thrive and now this government proposes taking away what little protection there is.

The proposed bill states that activities that are harmful to species cannot be carried out unless they have been registered – so basically there is no protection at all, register your plan to destroy life and then go ahead, and do it?

Regarding the reduction of duplication with Federal Legislation – I am not in favour of this. I think it is far easier to bribe a government official on one level, than on both levels. I am not naive, I know that it is possible to bribe any number of people at any level of government, but when we take away Federal protections for species at risk, and only have weak provincial protections, I think it is far easier for developers to get what they want and do what they want.

I am astounded that the government feels that they can take away recovery strategies and management plans, and have it as a free for all, do what you want after you have destroyed the land. Magret Thatcher believed everyone had the same moral standards as she did, she decided to deregulate the building industry, because of course people would build safely and not take short cuts and look at the fallout of that policy. The inherent truth about humanity is that we are greedy and will take short cuts, without thinking of long-term consequences. The whole reason we have these laws in place is because humans have proven time and again that we need them in place to protect the land and the people living on it. We can’t even provide clean water to indigenous and rural populations with the current legislations in place, and the Ontario government wants to deregulate what we have – how many disasters will we be faced with then?

We have a Species Conservation Action Agency in place, which has taken approximately 4 years to become established – hasn’t done any work yet, but just at the point where it can be effective, the Ontario government is planning on shutting it down, wasting all that start-up money, and starting a new species conservation program… and stealing the money from the SCAA to go to the government? This reminds me of the blue licence plates in Ontario – no one asked for them, no one tested them, huge amounts of taxpayer money were spent on the program, only to find out after they had been distributed there were huge legibility issues, especially at night. So, the program got scrapped and the money wasted, and somehow everyone forgot about it? Or when Ontario changed the name of the CCAC (Community Care Access Centers) to the HCCSS (Home and Community Care Support Services, and then to Ontario Health at Home, even though essentially there was no change in function. However, there was a huge cost to change websites, stationery, signage etc. All taxpayer money wasted. It is probably better to keep the SCAA and let it do its job, rather than setting back the clock 4 years and having a new committee start again, wasting more taxpayer money.

So, if there are not going to be Advisory committees anymore, then who, at the government level, is actually fighting for the rights of the environment and the people? I find it interesting that this Ontario government feels we should just trust them to do the right thing – when time and again, they haven’t. I present Ontario Place, the Ontario Science Centre, and the Greenbelt as examples.

Who will determine harm to species? The proposal states updated compliance and enforcement, while environmental protections have been stripped. It’s not as if the trees, the beavers, the bees, etc. are able to state that they have been harmed. No tools to enforce weak laws if someone determines no harm done? The loopholes in this proposal are so obvious I feel I shouldn’t have to point them out, yet they are in the proposed changes, so perhaps no one has seen them? Or perhaps it was hoped that the loopholes wouldn’t be noticed…

Registration first approach has so many flaws. Let’s take that into a field that makes it more relatable. Let’s take healthcare. Imagine if a person could register their intent online to practice medicine and then just go ahead and do so, without education or training. Or perhaps they have some education and training, but didn’t pass their final exams and practicums. They registered online with no one to review their application to work in medicine, or maybe do surgery. You know, maybe this is the solution to the doctor shortage in Ontario – why wait for medical students to finish their studies, surely, they know enough after a year or two to practice medicine. Get rid of the licensing, just have them register online, I am sure it will be ok…

So, in short, I am not in favour of the proposed changes and feel it is yet another attempt from the Ontario Government to undermine the province, to let developers develop unaffordable housing wherever they want, so they can be rich, and the people of Ontario lose their natural spaces, and still can’t afford housing.