Proposed changes to the…

Numéro du REO

025-0380

Identifiant (ID) du commentaire

147403

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Individual

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Proposed changes to the Species At Risk Act, 2007 are extremely problematic. These changes would result in less protections for listed species in a number of ways. Listing of species must be based on science and the scientific team making assessments must be independent of the government and the Cabinet; decision-making should not be discretionary. Ministerial powers should not be designated. Protection of species at risk should not be influenced by economic considerations as this most certainly undermines the point of protection.
Of great concern are changes to the definition of habitat to limit it to dwellings and areas around dwellings or the critical root zone. This does not take into account additional areas required by species, which are far broader than the dwelling area. Biologists recognize that species require different areas for different life processes, especially foraging, however many species require different locales for mating, nesting, and overwintering as well. Without these additional areas, species are unlikely to survive. With respect to plants, the limitation to root zone could amount to the soil directly outside of the root zone being removed leaving a column remaining around the plant; we know would not work for many plants and would result in their death.
Removal of the word harass from the list of prohibited actions may have extremely negative implications. Unfortunately, there are some people who may continually harass an animal such that it leaves an area and subsequently does not survive; this would then allow unfettered development. This does not safeguard wildlife.
The wording of the permit process is questionable in that it sounds as though no individual will actually review the registrations and ensure they are based on reality. Biologists must review permits and continue to create recovery strategies, management plans, and progress reports. Instituting a new permitting system without defining the regulations first is a questionable process and is not transparent.
I note that the government intends to repeal the Endangered Species Act, 2007 altogether and replace it with a Species Conservation Act. This certainly makes it seem that Ontario will no longer protect species at risk and wants to make it seem that there are no endangered species. We live in a capitalist society already; legislation and regulations are required to maintain a quality of life for people and biota otherwise we will cease to exist. Withdraw Schedule 2 of Bill 5 and continue to protect species at risk. Money is transitory. Life is not.