The proposed changes to the…

Numéro du REO

025-0380

Identifiant (ID) du commentaire

146264

Commentaire fait au nom

Individual

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Commentaire

The proposed changes to the Endangered Species Act and proposed Species Conservation Act show very little concern for the actual conservation of species, and instead demonstrate a bias towards economic development. Unfortunately, this proposed approach seems to put Ontario's wildlife -- a highlight of our identity as a province, and as a part of our beautiful country -- in jeopardy. As an Ontarian, I greatly value wildlife and the natural spaces found in our province and I feel strongly that they are an important part of my identity. This proposal describes with great evidence the intention to greatly reduce the protection that endangered and at-risk species will receive. The existing definitions and protections of the ESA should be retained. The new definition of protection claims to "focus on the core protections essential to conservation", but the proposed redefinition of "habitat" will essentially eliminate protection for the areas used by species. Space beyond the species' immediate home or root system are also essential to their lives. Isolating protections to these limited spaces only will leave species without space essential for their survival and conservation. Animals require sufficient space to travel, forage, hunt and reproduce. Plants require land to acquire sufficient nutrients, water, and maintain the appropriate environment for growth and reproduction. The current definition of "habitat" is purposely vague, to ensure that species are allocated appropriate space based on their species-specific needs (Endangered Species Act, 2007). Furthermore, the proposal describes how activities that may harm species are permitted to proceed so long that they are registered, blatantly describing that there will be zero prevention of this harm from occurring. At the bare minimum, legal protection for threatened and endangered species should continue to exist on government-owned land. Ideally, the government could provide incentives for the continuation of species protection on privately owned land, despite the ability to cause any harm upon registration of a project. The budget for the proposed SCA is sufficient to support incentives to continue conservation on private land. Finally, the new legislation must respect Indigenous rights and their duty to consult. This proposal is not favourable to any Ontarian who values our wildlife, and especially the conservation of endangered and threatened species. It is evident that this proposal will leave species without sufficient protection, and support development despite the severe harm it will cause. Improvements could be made to eliminate the bias towards development, and to instead have a true balance between species conservation and development in Ontario.