Reduce, Delay, Weaken, Over…

Reduce, Delay, Weaken, Over-rule, By-Pass and Less Enforcement of ESA sucks.

10th Year Review of Ontario’s Endangered Species Act: Proposed changes (ERO 013-5033)
Posted by Ministry of the Environment, Conservation and Parks on April 18, 2019
Public Comment Period April 18, 2019 - May 18, 2019 (30 days)

As an Ontario Resident and Taxpayer I absolutely object to the changes proposed to the Endangered Species Act (ESA) as outlined under ERO #013-5033 in entirety. The changes are a blatant attempt to undermine the ESA in intent, effect and enforcement.

I object to lengthening the time from when a COSSARO report is received by the Minister to listing the species on the SARO list from 3 months to 12 months. The situation must be dire before COSSARO adds a species to the list so this proposal would steal a critical 9 months of species and habitat protection.

I object to limiting COSSARO’s ability to submit a request for species protection to the month of January. Once COSSARO has determined that a species should be on the SARO list, action must be immediate.

I object to building in a delay tactic to further detriment of species by allowing the Minister of the Environment to require COSSARO to re-assess species classification.

I object to requiring COSSARO to consider a species’ condition around its broader biological relevant geographic area, inside and outside of Ontario as the requirement is immaterial to Ontarians today and to future generations. The goal is not simply to preserve the species, but to preserve the species for Ontarians.

I object to broadening COSSARO membership qualification to include “community knowledge” as it would reduce the scientific expertise of the panel and thus would call decision-making into question. The highest level of scientific expertise and traditional aboriginal knowledge is required for purity of intent and credibility.

I absolutely and utterly object to de-coupling the listing process from automatic protection and giving the Minister (most of whom are scientifically unqualified for the job and hold the office for less than 2 years) discretion on protections.

I object to allowing the Minister to have discretion on protections with the authority to temporarily suspend species and habitat protections for up to 3 years as such power would make the Act inconsistent in its application, capricious based on political climate and unfair to some applicants.

I object to by-passing the Environmental Bill of Rights, 1993, which I consider informative and useful.

I object to transferring authority from COSSARO, an independent scientific based board, to the politically engaged Minister of Environment easily influenced by the political climate.

I object to establishing the Species at Risk Conservation Trust, independent Crown agency [independent of what?] to allow municipalities or other infrastructure developers the option to pay a charge in lieu of completing certain on-the-ground activities required by the act.

I object to the whole premise of municipalities or other infrastructure developers being able to “pay to slay” species of concern.

I object to moving enforcement from the Ministry of Natural Resources with a network of already trained and respected conservation officers to the jurisdiction of the Ministry of Environment.

I object because the proposed changes to the ESA are entirely contrary to my review and comments submitted in January 2019.

The current government was elected based on Doug Ford’s promises to be “For the People” and to “restore accountability, respect and trust to Queen's Park”. I don’t see those promises being fulfilled in these proposed changes.

Please do not enact the changes as proposed.