May 18, 2019 RE: ERO 013…

May 18, 2019

RE: ERO 013-5033
10th Year Review of Ontario’s Endangered Species Act: Proposed changes
The Ottawa Field Naturalists’ Club opposes the changes to the Endangered Species Act proposed in Schedule 5 of Bill 108, and asks that they be rejected entirely.
At a time when the loss of biodiversity is accelerating, protections for declining species and their habitats need to be strengthened, not weakened. The modern crisis of biodiversity loss and rapid extinction was very recently highlighted in the Global Assessment from the United Nations. Anytime a species disappears, the ecosystem loses that species’ function and contribution to biodiversity. That ecosystem may be less resilient, and the loss of some species may cause a trophic cascade of negative consequences. Preserving biodiversity is key to ensuring ecosystem health, which in turn affects ecological services including the supply of clean water, pollination, and the ability to slow or even counteract the effects of climate change.
The proposal to reduce or remove the at-risk status of Ontario species that are either at the edge of their range, or that are not at risk elsewhere in their range, is particularly alarming. For species to be conserved appropriately, they need sustainable populations throughout their range. Failure to protect Ontario populations of any species falsely assumes that the causes of decline in Ontario will not occur elsewhere. Nearly all of Ontario’s species at risk are threatened by some combination of habitat destruction, habitat fragmentation, invasive species, and direct persecution. These phenomena are by no means restricted to our provincial boundaries. Ontario has a responsibility to conserve its share of the populations of its native species, be they large or small.
Furthermore, the peripheries of the distributions of species are genetically important, for those populations are the ones most adapted to extreme conditions relative to the species’ core range. Conserving these populations is critical to ensuring that individual species can adapt to and survive the effects of climate change; conversely, not protecting these peripheral populations would inhibit a species’ ability to adapt or shift its natural distribution in response to changing conditions. When the population of a species in Ontario is at the limit of its natural distribution, our collective responsibility to protect it is greater, not lesser.
Also particularly concerning are proposed provisions that would allow a Minister or the government of the day to override the ranking of a species at risk or its protections, in spite of scientific evidence or advice. In order to be both credible and responsible, the classification and ranking of species must remain evidence-based, and legal protection should flow from this. Short-term economic or political gain does not justify the permanent destruction and loss of our natural heritage.
In order to preserve Ontario’s biodiversity, ecological health, and natural heritage, please remove the entirety of Schedule 5 from Bill 108.

Sincerely,

Diane Lepage
President, Ottawa Field-Naturalists’ Club

Jakob Mueller
Vice-President, Ottawa Field-Naturalists' Club

Owen Clarkin
Chair, Conservation Committee, Ottawa Field-Naturalists' Club