In regards to changing…

In regards to changing Endangered Species legislation - as an architect, I would be fine with changing regulations to avoid duplication. Or to add prescriptive requirements to development projects like a Building Code where people who are proposing to impact natural environments know what the regulations are BEFORE making a proposal rather than having it reviewed after a proponent has spent a lot of money developing ideas for a project. An example of this would be a marina that impacts fish habitat.

As a conservationist and citizen of this province, endangered species legislation first has to PROTECT rare species. In Ontario we have failed to protect species like Bobwhite, Caribou, Black Tern, Badger, and Foxsnake and many others which are all declining. Karner Blue Butterflies were extirpated in my lifetime from an area managed by the Ontario Government (St Williams Forestry Station.) All of these were common species which have declined in my lifetime despite all the best intentions. The Foxsnake was recently delisted from Endangered to Threatened in spite of the fact the total area the species occurs in has declined in the last thirty years (in its very small range in Canada and the US) and there is no evidence the population is increasing anywhere the species occurs.

Legislation has been totally ineffective at protecting the Eastern or Algonquin Wolf because complexities in taxonomy to avoid dealing the issue of whether this population needs to be protected. Almost no effort has been made to work with communities around Algonquin Park to educate them about the significance of the wolf populations there or encourage the development of ways to live in harmony with wolves. People are afraid of wolves but that fear can be unlearned.

More important for me is to protect natural areas and the ecological systems that harbour common and rare species alike. This government sought to allow areas of the Greenbelt to be developed, and has allowed significant areas of wetland in the province to be filled in to facilitate economic growth. This is not a wise policy nor is relaxing our already insufficient protections for natural environments as is proposed by the changes this legislation.

As an example, since the arrival of European settlers more than 68% of wetlands have been lost in southern Ontario (attached is a map from the publication from Applied Geography, 138 (2022) 102625 showing the extent of this). These wetlands, like other types of natural habitats, are essential for maintaining ground water, soil quality, binding carbon, and reducing the impact of catastrophic flooding. The slow degradation of the role of Conservation Authorities in Ontario to protect watersheds (by most recent governments) have shown we have not learned the lessons from Hurricane Hazel or appreciate the increased risks of flooding that are on the horizon.

And yet, restoring and conserving the ecosystems of our natural infrastructure is the most cost effective ways to mitigate the impacts and costs of climate change.

The stated intention of the proposed change is to help speed up project timelines and provide greater certainty for proponents, because the process to obtain a permit is slow and complex, causing unnecessary delays and costs for housing, transit, and critical infrastructure. This effort puts the interests of private individuals and businesses and short-term gains ahead of the common public interest. Who pays insurance claims after a storm or for infrastructure that is damaged by flooding, or loss of fish in lakes, or for the repair or maintenance of roads and water and sewers after storms – tax payers. There may be ways to stream line legislation and find ways to make the process more transparent, but in my experience with development, most people already know the process and are really finding away around the rules for their own personal benefit.

It is the government’s role to promote business because that is what generates income and wealth, but is it also the government’s role to protect the public interest. Only the government can protect the public interest like natural resources, or features like air or water and species that are not bound by arbitrary property lines.

Endangered species are the “canaries in a coal mine” – if they are rare, they indicate there is a problem in the environment. A problem that sooner or later will affect us. Legislation to protect endangered species and the habitats in which they live, should be conservative – because once you lose it, you CAN’T get it back, and if you can, it is not easy. Most Ontario governments have not done a good job protecting endangered species or natural areas. Even so, Ontario’s Conservatives have been some of the most forward thinking governments in that they established the first parks, put the most area into Parks and enacted legislation like the Oak Ridges Moraine. Please continue that tradition of forward thinking.
On a related matter, I would rather there be really clear rules and a fair process for resolving disputes. But the process should protect the long-term public interest. If a rare species, designated wetland or habitat occurs on private land and it is in the public interest to protect that value – the owner of the property should receive a benefit – perhaps a tax credit in an MPAC land use category. Protecting our natural environment should not be a “take away”. In Ontario (and in many places), there is currently no such way to reduce the value of your property because you can’t develop it because it is an important natural area. The Conservation Land Tax program is onerous and has to be renewed each year – THAT is inefficient. The Ontario Government should find a way to remove the financial consequences of private land owners who protect our shared natural resources.