I work as a consulting…

I work as a consulting ecologist in the province of Ontario, working on many projects that require Endangered Species Act registrations, permit applications, habitat screenings etc. Some components of this proposal make sense - for instance the creation of clear outlines for the processes and timelines of an application. Everyone wants the process to be more clear, punctual, and predictable. However, it is my experience that much of the time lag on reviews is squarely in the lap of this government having refused to hire the appropriate number of experienced staff to handle reviews in a timely fashion.

There are also MANY provisions of this proposal that I vehemently disagree with, both as an Ontario taxpayer and an environmental professional. For example, the very idea of limiting the definition of an animal's habitat to it's den or nest, or a plant's to its critical root zone is such an absolute slap in the face to the principles of conservation biology, that it betrays that no trained biologist or ecologist had any hand in writing this proposed legislation. To describe it in laymen's terms - this idea is tantamount to locking a person in their bedroom, tearing down the rest of the house around them, and expecting them to not only survive this experience long-term, but to thrive and have children in such conditions!

In a more technical sense, the reason most of these Species at Risk are at risk is because their habitats have been destroyed or altered in such a way that they are no longer conducive to that organism reproducing at a rate maintaining a healthy sized population. American Ginseng only grows in the wild in forests. It requires forests because it requires the shade - not only to keep it's shade-intolerant leaves from burning, but to keep the soil around it moist. It requires forests because it requires the calming of the wind - not only to (again) keep the soil around it moist, but to keep it's shallow root system and the soil it's in from blowing away. These two factors alone mean that American Ginseng tends to decline in population when a new forest edge is created within 90m of a population. Sudden clearing of forest creates new edges on the remaining forest where the trees which were once growing in the interior are now impacted by winds of previously unencountered strengths and directions, increasing the likelihood of wind throw or canopy breakage. In other words, clearing the forest edge to make room for a development, makes it more likely for many of the remaining trees to fall during a storm, which creates more canopy gaps or edges.

There are so many other variables at play that impact a species' ability to thrive in it's environment than simply the immediate ground it is touching. So I must say again, that this proposed policy must either have been written by someone without the knowledge to assess what qualifies as habitat, and/or by someone who does not care about the inevitable crash in population these species will undergo as a result. They are wholly unqualified to make this proposed change, whether by ineptitude or by malice.