With respect to the 10th…

With respect to the 10th Year Review of Ontario's ESA:

1. I disagree with allowing developers and other proponents of harmful activities to pay into a fund in lieu of fulfilling requirements for on-the-ground compensation. This easy way out reduces accountability and makes it far easier to proceed with activities that harm species at risk and their habitats.

2. The Committee on the Status of Species at Risk in Ontario (COSSARO) is a committee comprised of qualified scientists who perform science-based assessments of whether a species is at risk. I disagree with the proposal to broaden COSSARO membership so that it includes those with “community knowledge” – a vague term that could open up COSSARO to those who do not have adequate expertise in species assessment or have a different agenda altogether.

3. I disagree with basing COSSARO’s assessments on the status of a species throughout its range. For Ontario listed species, they should be based on Ontario’s distribution.

4. I disagree with provisions that would allow the Minister to limit ESA protections so that they apply only in specific geographies or under specific circumstances. This could exclude important habitats and species from protection.

5. I disagree with the proposed Ministerial veto of automatic protections. The listing of species at risk should not be be “de-coupled” from automatic protections for threatened and endangered species and their habitats.

6. I disagree with the proposal to allow the the Minister to suspend species and habitat protections for up to three years based on social or economic considerations.

7. I disagree with the proposal to create “landscape agreements” for proponents undertaking harmful activities in multiple locations. Such an approach does not lend itself to addressing site-specific or species-specific concerns and consequently presents unwarranted additional risk for species already in peril.

8. I disagree with the proposal to allow activities approved under other laws to be carried out without any additional authorizations under the ESA, especially if they harm threatened or endangered species or their habitats.

9. I disagree with the removal of the requirement for the Minister to consult with an independent expert prior to creating regulations that jeopardize the survival of a species, or for issuing permits for harmful activities that would provide a significant social or economic benefit to Ontario.

10. I disagree with the proposal to list species nine months after COSSARO makes its assessments public – during this time vulnerable plants, animals and their habitats could be eliminated before protections kick in.

As a resident of Ontario, I am not okay with these proposed amendments. Please repeal the proposed changes to the ESA and protect Ontario’s species at risk.