Although I believe that no…

Although I believe that no amount of public input will alter the current government's intent to pass these proposed changes, I would like to note the following:

1. Allowing a government minister to use their discretion in adding species to the endangered list, or in delaying actions that protect them, completely politicizes the process. This is not at all in keeping with an arms-length decision based on scientific facts.
2. The consideration of a species' status throughout its wider geographic range is misleading and inappropriate. It has been clearly established that the resilience of most species is dependent on interactions among separate populations, such as allowing for the flow of genes and movement to favorable habitats depending on year-to-year conditions (e.g., drought, forest fires, etc.). Letting some populations decline is therefore usually the first step in endangering the entire species.
3. It is discriminatory to citizens in certain regions of Ontario to not have access to protected environments, including the organisms that live there, due to exemptions. Should the experience of wildlife by citizens therefore be limited to those residing in areas with relatively little economic activity, or involve traveling outside of their region? All citizens have the right to experience nature - this is not for the government to arbitrarily decide on their behalf.
4. Allowing parties to "pay a charge" in lieu of actual acts that promote the conservation of species directly affected by their activities will clearly result in local biodiversity declines. The use of the proposed fund resulting from such charges is poorly described, and it is not apparent that it would be even be used to promote local conservation. If it is part of some general fund that funds conservation elsewhere, once again citizens in the affected area bear the brunt of negative impacts with no say.
5. Based on the wording of the proposed changes describing conflict with "economic benefit," the latter is not defined in its scope. Would economic benefit need to be demonstrated with a dollar amount? Would it be a one-time benefit, or on-going? How does the scale of harm to endangered species compare to that of the economic benefit? Is any economic benefit enough to outweigh harm to endangered species?

In sum, I view these proposed changes as a significant weakening of current policies to shift from an automatic process with concrete timelines that is conducted by an arms-length agency employing actual scientists who use data to a politicized process full of exemptions and weak timelines to support a vaguely-worded goal of economic benefit. It is not all in keeping with the well-established guidelines and policies used by conservation agencies worldwide, and it is fairly shameful that we are moving away from evidence-based decision-making.