I recognize the importance…

I recognize the importance of increasing the economic growth of Ontario and meeting housing needs, but this does not need to happen at the expense of lesser protections for endangered species.

In regards to the proposal I have specific comments below:

1.
“ The government would also have discretion to remove protected species from the list [of protected species]. “
I believe this is a short sighted and ultimately negative choice. If the government already authorizes the independent organization of the COSSARO to scientifically evaluate the classification of species, why else would the government award itself the right to remove protected species from the list? Removing scientists from the equation only allows government officials to make non-scientific and potentially political decisions that, ultimately, may result in the further destruction of a species. This lack of an evidence based approach is detrimental to broader society and not what I would expect from a government that is interested in protecting its natural resources. I propose that the government does not give itself the right to remove protected species from the list, and keep the rest of the proposal under “species classification and listing” the same.

2. “Redefining protections
for animal species:
a dwelling place, such as a den, nest, or similar place, occupied or habitually occupied by one or more members of a species for the purposes of breeding, rearing, staging, wintering, or hibernating
the area immediately surrounding a dwelling place described above that is essential for the purposes mentioned“

I am concerned with this above proposal, because while the overall proposed change is meant to decrease ambiguity, the area “occupied for the purposes of …” is also ambiguous. I am notably surprised by the lack of consideration for animals that migrate or require unfragmented habitat to thrive, such as our threatened caribou species in Northern Ontario and the Eastern Wolf. On the Ontario species at risk website, the government itself acknowledges that

“ Threats to the boreal population of caribou include habitat loss, degradation and fragmentation due to human settlement and development activities such as forestry, mining, hydro corridors and roads. Caribou are also at risk from an increase in predation and disease that accompanies such broad habitat changes. Between 40 to 50 per cent of caribou range in Ontario has been lost since the late 1800s.”

I am concerned that the new language in the proposal is too narrow, and defines the land necessary for preservation of a protected species only as the land immediately surrounding its “den”, and would not adequately be applied to land used by caribou and other ranged animals, as well as birds. This change may cause further damage to the land necessary for the survival of boreal caribou, and coupled with other threats against this animal, may cause it to become more endangered.

Furthermore, aerial insectivore birds have decreased by 43% in the past 50 years according to the 2024 State of the Birds report by Birds Canada, indicating that the current methods are not adequately protecting them in this country. Birds are unique in that while they do have a nest as their home, many migrants also require suitable habitat conditions that can sustain them as they migrate to a nest site. A core range designation would help protect the ranges they need to survive.

I propose including the terminology “core range” in the list of areas to be associated with protecting species under the new proposal. Scientists and the government have range data for these species, and thus can designate particular core areas of importance for these species, and these areas could be developed mindfully for use by industry. Areas that are pre designated as being unlikely to contain or be used by species at risk can be more easily registered by development by industry than these ranges. This language is not only more specific than the original ESA, but now promotes a more efficient and mindful development of Ontario’s land which still considers the land use needs of our species at risk.

3.

While I support the non-duplication of federal and provincial reviews, I think the province should practice foresight and also state that they will continue to not provincially oversee the following of federal SARA laws as long as they exist for protected protected aquatic species and migratory birds. This is to ensure Ontario is protected even from changes that occur at the federal level.

4.
I support the new investment into the Species Conservation Plan, which I think is a good step that the government is taking to protect our land in Ontario. I am concerned that the government is removing “ requirements to develop recovery strategies and management plans, government response statements, and reviews of progress from legislation. ” I am worried that without this requirement, the government would not be required to follow up with all the measures taken to address endangered species, and therefore some measures may not help protect them at all. I propose at least a light framework of requiring species data reports for endangered species, so that the government and the people are aware of the current threat assessments and what measures taken by the government are working.

5. While I am not against the removal of the requirement of an advisory committee, I believe the government should include a requirement for scientific guidance on projects that may affect endangered species. This provision should be engaged in a need-to-use basis depending on the location and scale of a development. The government should be following evidence for our future based on science and not the opinions of politicians and industry. Therefore an independent consultation of environmental scientists when necessary is the common-sense approach.

I hope these comments are considered and helpful in the writing of the new proposal. Ontarians want a future that is both safe for us and our environment. Thinking generations ahead and taking the right steps to protecting species now is a part of that.

Thank you
Constituent, Oakville North-Burlington