The stated objectives of…

The stated objectives of this proposal are
• “to enable use of the Species at Risk Conservation Fund (the Fund) and to establish a provincial agency to administer the Fund” and
• “to amend Ontario Regulation 242/08 to streamline Endangered Species Act authorizations by amending certain conditional exemptions.”

These objectives are contrary to items 2 and 3 of the Purposes of the Endangered Species Act:
2. To protect species that are at risk and their habitats, and to promote the recovery of species that are at risk.
3. To promote stewardship activities to assist in the protection and recovery of species that are at risk. 2007, c. 6, s. 1.

The Endangered Species Act is intended to protect species at risk and their habitats. The Act is NOT intended to make life easier for proponents. Generations of development activities have brought us to the situation where we are today – large numbers of species in serious decline. This further reduction of the protections in the Endangered Species Act turns the clock back to a time when the environment was overlooked in decision-making. In the 21st century, our society is supposed to know better. Ontario must take science-based actions to protect species at risk.

In May of 2019, the United Nations, through the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services, reported that nature is declining globally at rates unprecedented in human history. The rate of species extinctions is also accelerating. In the face of this science, Ontario should set aside the concept of the Fund, and instead move to strengthen protections for endangered species and their habitats.

The proposal outlined in ERO 019-2636 abandons the concept of overall benefit to the species. What standards will be used to inform decisions around the Fund? What monitoring programs will be implemented to evaluate the condition of affected populations of at-risk species? How will a proponent, or the government be able to create safe and productive habitats for at-risk species? The creation of new habitats is extremely difficult, will have unforeseen economic costs, and unknown benefit to the at-risk species.

Habitat loss and degradation are key factors in the decline of whippoorwill, bobolink meadowlark and Blanding’s turtle. With the Fund focused on exemptions and permits to expedite development (i.e. destruction of habitat) the Fund will inevitably contribute to the decline of these species.
The proposal says that funds may be pooled and used to benefit other species, not necessarily the one being impacted by a specific project. This is inappropriate. If there must be some sort of Fund, then there must be a direct linkage from an individual project or proponent to the compensatory action. Furthermore, the results of any mitigation and compensation carried out through the Fund must be reported in a clear and traceable manner. Traceability is not part of the current proposal.

I do not support the government’s plan to proceed with the Fund. The proposal would lead to increased habitat loss and degradation. The proposal works against the protection and recovery of at-risk species. The proposal fails to account for additional risks to species already threatened with extinction. It fails to ensure transparency regarding site-specific and cumulative harm to the habitat of at-risk species.