I am strongly opposed to the…

I am strongly opposed to the proposal to repeal the Endangered Species Act (ESA) and replace it with the Species Conservation Act (SCA). I'm also strongly opposed to the immediate amendments to the ESA.

I believe this proposal marks a massive step back from evidence-based policy principles and would see the erasure of science from Ontario's endangered species legislation. Giving the government the ability to add or remove species from protections regardless of COSSARO assessment is irresponsible and dangerous. The government does not have the expertise nor the capacity to make these decisions in a way that considers the complexities of ecosystem functions and ensures unintended consequences are avoided, both ecologically and economically. There is a reason an independent scientific body was appointed to make these decisions, and why multiple ministries are involved in preparing recovery strategies and government response statements. This is a blatant disregard for science.

The proposed definition for habitat is another example of ignoring scientific evidence. It is well established in the scientific literature that species habitat needs are much more complex than an area to support a dwelling. Not only is the absence of an area to gather food/meet nutrition requirements a glaring gap in the proposed definition, but it is well accepted that in order to promote species conservation and recovery, species require habitats that meet other needs like movement, the support of social systems, and ecosystem connectivity. If a forest is cut down but a sole tree remains on the side of a new highway because it housed a bird's nest, that bird will, in the best case scenario, move to search for another habitat that meets all of its needs, or at worst will not survive because it is not able to meet all of its needs.

The proposal also removes all government accountability for species conservation and recovery. Without a requirement to develop recovery strategies, management plans, government response statements and reviews of progress there is no mechanism to hold the government to account for protecting species. As the government continues to slash funding for environmental programs in the name of economic development, without these policies, there will be no reason for the government to continue funding enforcement activities, conservation initiatives, and stewardship activities. This proposal may claim that spending for conservation and stewardship will increase by four times but what will stop the government from walking back that promise as they've walked back so many others? It also marks a decrease in transparency and collaboration.

The proposal does not provide enough details on the proposed Species Conservation Act for the public to make informed comments. There are no details on the proposed registration-first approach. What will be the requirements individuals must follow in order to proceed with their activity? In order to provide any mitigating measures to avoid a massive decline in populations, the regulations should include species-specific guidelines that operate on the precautionary principle. The registration-first model carries a huge risk that by the time the government is aware of a potentially disastrous activity it will be too late to stop and could result in irreversible impacts. I believe it is also worth noting that even with the stronger protections under the current ESA, many at-risk species are still in decline. With the new registration-first approach it is almost guaranteed that populations of species will decline at larger rates than we've seen in the last two decades.

Further, this government should know first hand the society-wide devastation that can happen when ecosystems are threatened. Many infectious diseases are spread throughout the world because human settlements encroach on wildlife habitat. Healthy and diverse ecosystems where wildlife has ample room to survive without needing to enter human settlements is the best defense against new and emerging disease threats, not just to humans, but to domestic animals as well (like Avian Influenza). These diseases, bacteria and parasites that spread more when ecosystems are in decline threaten our economy (e.g., agriculture) and the health and well-being of Ontarians. This proposal puts us at higher risk of another epidemic.

Overall, this proposal makes it clear that the government does not understand or care about sustained economic performance of this province. Healthy ecosystems are diverse ecosystems. Without healthy ecosystems many of our most powerful sectors - agriculture, manufacturing, tourism, and more - will suffer in the long term. I urge the government to stop using the trade war as an excuse to move forward with short-sighted political maneuvers that favour their friends and put the long-term health, sustainability, and economic prosperity of the province first.