I am a professional…

I am a professional biologist specializing in the ecology and conservation of wildlife. Over the past 15 years my research team has received multiple grants from the Ontario government for research on species at risk in Ontario and we are working closely with a range of organizations, including Indigenous communities and members of the public, to understand and help protect species at risk in the province. I have provided expert testimony in environmental tribunal cases dealing with wildlife conservation issues and regularly provide collaborative expert advice on species at risk to industry (forestry and mining companies, environmental consultants). I have also been involved in the COSSARO, and federal COSEWIC, listing processes for species at risk and have helped develop both provincial and federal recovery plans. Given the proposed funding to be added via a new “Species Conservation Program” it is possible that my research team might benefit financially from some aspects of the proposed legislation. Nevertheless, I write in the strongest possible opposition to the proposed changes to species at risk legislation for Ontario.

The proposed changes will expose already threatened species and ecosystems to vastly greater harm. Moreover, while the proposed changes are intended to “unleash” the economy, they fail to account for or protect the tens to hundreds of billions of dollars in ecosystem services provided, free of charge, by Ontario’s environment to the citizens of Ontario. The value of ecosystem services is much more difficult to quantify than the value of industrial development which is why it is so often under-valued. However, the dollar value of ecosystem services for jobs, the economy and society are enormous. Despite their intended purpose, the proposed changes will “unleash” enormous harm to Ontario’s economy.

I have great respect for the public service provided by elected politicians but this service only works when politicians seek out and accept expert guidance. Good elected officials do not make uninformed decisions about, for example, operations at a nuclear power plant or an air traffic control system or the specifics of a public health response. Good elected officials rely on the best evidence and the best experts to make impartial, evidence-based policy decisions. Ecosystems are extraordinarily complicated and it takes many years of training to understand how to make good decisions and recommendations about their protection. Reducing the role of COSSARO from the species listing process, and handing over complex decisions about which species to add to (or clearly much more likely, remove from) the species at risk list, is a terrible idea, not just because it will result in harm to the environment, but because it will place politicians in the terrible position of being responsible for uninformed decisions they are not qualified to make, without having to rely on the best evidence and expertise at their disposal.

The “registration-first” approach is also a terrible idea that will have profoundly negative impacts on species at risk and ecosystems. I know from direct experience with the environmental tribunal process and advising on multiple industry projects that, had permit review not been required before a project was started, irreparable harm would have been caused to populations of at-risk species. Quality environmental impact assessment does take some time and resources but there is enormous value in this process for protecting nature and the economic benefits nature provides for society, as well as reducing potential for future conflict between industry, the government and local communities who want to protect the environment. Watering down this process, and allowing projects to go ahead before they’ve been properly reviewed, will have devastating impacts on the environment and lead to unnecessary and costly conflict.

The proposed changes to habitat definitions, and removal of “harassment” from legislation are also short-sighted and ill-informed. Anyone who knows anything about wildlife knows they require far more than just breeding and hibernation sites to survive and reproduce. They also know that “harassing” (or even mildly disturbing) many wildlife species can have dire impacts for populations. These changes are a terrible idea which will inevitably exacerbate species declines for wildlife species as diverse as caribou, bats, migratory birds, and fish, all of which benefit ecosystems and contribute economic value to society.

I am, by no means, opposed to economic development and I think responsible development can go hand-in-hand with wildlife and ecosystem conservation. I have advised multiple companies and organizations about how to operate in ways that reduce impacts for, or even benefit, wildlife species. I also think some aspects of the proposed legislation could be beneficial, particularly where there is clear duplication of federal and provincial activities. However, the vast majority of the proposed changes are poorly informed, counter-productive and antithetical to responsible economic development and environmental stewardship. In addition to causing enormous harm to Ontario’s natural resources, and negatively impacting the economic benefits of nature for Ontarians, the changes seem very likely to bring the Province and industry into conflict with Indigenous communities, other concerned members of the public, as well as the federal government (when these new provincial processes inevitably fail to provide adequate protection for species at risk). For all of these reasons I argue strongly against these proposed changes and urge the government to reconsider this poorly thought-out and, indeed, harmful legislation.