ERO 025-0380 Comment 1A - I…

ERO 025-0380

Comment 1A - I’m glad that the government would have discretion to add extirpated, endangered, and threatened species to the list of protected species.

1B - The government SHOULD NOT have discretion to remove protected species from the list. Removal of species from the protected list should only be done by the Species at Risk Advisory Committee.

2A - the proposed reframed of the definition of habitat is too narrow, and seems to focus on dwelling rather than use of the area for ANY purpose by the at-risk species; it does not include the area necessary for food-finding or mating, for example. In addition, the proposed definition is limited to “the area immediately surrounding a dwelling place…” which is also too narrow; it needs to mention that the size of the immediate area is variable, based on the required territorial size and needs of the specific species.

2B - for vascular plant species: “the critical root zone surrounding a member of the species” is not enough, they also need enough ground area for sustained nutrition for continued health and growth. In addition, some vascular plants, including trees, need other species nearby for optimal health and nutrition. Limiting the protected area to just the critical root zone is too narrow, especially for a species at risk.

(Re 2A& B): This is the reason for the consultation process and the broader definition of habitat - because each species has unique needs (which may vary from the average exemplar of the class or family of related organisms) that must be identified by an expert in the field. This cannot be simplified to streamline construction applications, no matter the intent. Protecting our environment and at-risk species benefits us all.

3 - Recovery Plans and Documents: if there is duplication with the federal recovery documents, it would make sense to work with the federal government to make one application to both levels of government, and have the provincial level administer and process the applications then submit for federal approval and feedback.

BUT - registration (or permits) SHOULD STILL BE REQUIRED for impacts to migratory birds and aquatic species protected under the federal Species at Risk Act. Just because a species is protected, doesn’t mean that construction work (for example) should continue without proper consultation regarding each protected species (birds and aquatic species included) that use the affected area for ANY purpose.

4 - It seems that this bill is being pushed for an agenda related to certain construction or development activities that would benefit certain companies that are not quite at-arm’s-length from certain parties who are promoting this bill, rather than for the entire purpose of strengthening protections for at-risk species in Ontario.

So it behooves me to add:

Related to this bill is the proposed creation of “special economic zones” that would allow cabinet to approve major development projects without proper environmental assessment, public input or Indigenous consultation. I AM AGAINST the creation of these “special economic zones”, as this would undermine transparency, accountability, and Ontario’s duty to uphold Indigenous rights and treaties.

Thank you for your time and consideration.