April 11, 2021 Subject:…

April 11, 2021
Subject: Metrolinx Permit for Overall Benefit | ERO: 019-3403

Dear Honorary Jeff Yurek, Minister of the Environment, Conservation and Parks,

As a current Arbor Groundman and Environmental Planning student, I am commenting to provide my disapproval of the March 30th, 2021 Metrolinx application for a permit to conduct activities that achieve an overall benefit for a species under clause 17(2)(c) of the Endangered Species Act 2007. The permit is intended to allow the installation of two additional culverts to expand the Barrie GO rail line in the Township of King. However, in doing so 5700 sq. m of occupied Redside Dace habitat will be negatively affected, and one Category 3 Butternut tree will be removed.

This application seeks to use section 17(2)(c) of the Endangered Species Act 2007 to achieve approval for this development. This section requires that the Minister;
- deems that the applicant will provide an overall benefit for the species within a reasonable time frame or pays a predetermined species conservation charge,
- that reasonable alternatives have been considered that would not adversely affect the species,
- and that the permit requires minimum adverse effects on the species.
The reasonable development alternatives mentioned for the Redside Dace habitat as well as the compensation organized with the Toronto and Region Conservation Authority outlined in the application appear to be adequate for offsetting the negative impacts to this species. Yet although Metrolinx does propose to plant and maintain several more Butternut seedlings, this does not promise to generate another Category 3 individual, and seemingly does not create an overall benefit to the species.

It is in my opinion that this application should not be accepted until there are better alternatives proposed to minimize impacts on the Category 3 Butternut tree. Butternut trees have been an endangered species in Ontario since 2008 and with re-assessment in 2017 remain endangered. As the tree proposed to be removed is designated Category 3, this tree has not succumbed to the Butternut Canker disease that threatens the species, can be resourceful in determining resistance to the disease, and therefore should not be removed.

Thank you for your consideration.