As a citizen of Canada and a…

As a citizen of Canada and a resident of Ontario, I strongly oppose the proposed changes to the Endangered Species Act, 2007. The changes would remove many of the protections for endangered species in Ontario, including the protection of the habitats they live in and the treatment of these species themselves. Despite claims from the Government of Ontario to remain committed to species conservation, the proposal shows changes beyond simply making the process more efficient; it is a stripping away of the processes and permits which ensure endangered species continue to exist and thrive in Ontario, despite economic pressures to the contrary. The proposed changes are a continuation of recent trends to erode Ontario environmental protection laws, and go against what the Act was created for in the first place: species conservation. Additionally, these proposed changes would have adverse economic impacts on Ontario in the long-term with regards to the tourism industry and change the global image of Ontario away from a beautiful, nature filled province to an exploited industrial land.

As one of the fastest growing regions in North America, it is increasingly being identified that Ontario needs to adapt and strategically invest in infrastructure and economic activities. The Places to Grow Act (2005) and its amendments since clearly show this. However, while there an acknowledgement that this needs to be done with strong consideration for the environment, especially since northern Ontario is largely undeveloped, the Government of Ontario has stripped many of the environmental protections in the name of efficiency in recent years. The proposed changes to the Act would severely restrict the definition of what constitutes the habitat of a plant or animal, allow significant discretion by the Government of Ontario to remove species from the Protected Species in Ontario list, and allow for the harassment of species without registration or permit.

The proposed changes would change the definition of the habitat of an animal to just its dwelling place such as a den or nest. This makes no consideration for the range of life-critical activities for which an animal depends on its local environment. Species depend on the area around their dwelling place for survival: to gather or hunt food and as protection from the elements and predators. While the extent of the habitat of a species can be difficult to determine and can vary between species and local conditions, this is not an excuse to create an overly restrictive and generic definition. These species have complex interactions with their environment and the local ecosystem that we may not fully understand, and these proposed changes undermine that fact.

The discretion granted to the Government of Ontario in the proposed changes is particularly concerning. The discretion would allow for the Government of Ontario to remove species from the Protected Species in Ontario list without any requirement for scientific backing. Ontario has an organization dedicated to classifying and identifying species at risk, the Committee on the Status of Species at Risk in Ontario (COSSARO), but the discretion would allow for an overruling of the decision to include a species by those unqualified to do so. It is clear that the intention is to make the projects in Ontario a priority over the protection of endangered species. This is unacceptable as one of the main purposes of the Act is to ensure the protection of endangered species and their habitats regardless of the economic pressures.

The changes would also allow for projects to proceed without permits and only require registration of most activities involving endangered species. This is a flawed approach to species protection as it prioritises the activity over the species. This also does not allow for any mechanism to stop damage to the habitats of endangered species or the species themselves if it is found that the activity is having negative impacts. The evaluation of an activity on a species can be complex and lengthy which is exactly why a permitting process is required. Additionally, this extra permitting time delay can be a strong motivator for the project proponent to move their project elsewhere where the endangered species will not be affected or to conduct their project in a way which will lead to better outcomes for the species. With the new registration based approach, these motivations disappear.

These proposed changes go against what the Act was created for in the first place. The purpose of the Act is to require changes or halting of work from projects or activities where endangered species may be negatively impacted. The proposed changes undermine this goal and give the Government of Ontario the right to drive species to extinction where it aligns with their economic goals. These changes are part of a larger shift away from environmental protection in Ontario and will affect its global perception. Many tourists come to Ontario every year to experience the wonderful outdoors: beautiful beaches, forests, lakes, mountains, wildlife and much more. I hope that Ontario will take the necessary steps to protect this beauty for all of us today and for future generations.