Dear MPP Rudy Cuzetto,…

Dear MPP Rudy Cuzetto, Premier Doug Ford, and whom it may concern,

I am a recent graduate of University of Toronto with a degree in Environmental Management. During my studies I took a particular interest in Ecology and Ecosystem Management courses. My peers and I are greatly concerned by the proposed changes to the province’s primary existing piece of endangered species legislation. It is important to note that protecting endangered species falls mostly under the jurisdiction of the provincial government over the federal one.

Although there is certainly a need to streamline the permit process to accommodate rising demand for new development, it should not be done at the expense of Ontario’s biodiversity – the value of which cannot be understated or sold.

I am particularly concerned by the proposal to give the government discretion to remove species from the list determined by COSSARO, which directly contradicts the claim that the committee’s role will not change.

Ontario defines harassment of a species as “an activity...that disrupts its normal behaviour in a manner that adversely affects the ability of the member to carry out one or more of its life processes” (https://www.ontario.ca/page/policy-guidance-harm-and-harass-under-endan…). The removal of this term is completely counter intuitive to the entire point of having endangered species regulation.

The proposed updated definition of habitat goes against all that I have learned from my university education. One of the most crucial concepts that tied all the information together was “systems thinking”, which stresses a holistic view of the ecosystem in question. Nothing exists in a vacuum – especially not a den, nest, or root system. Each component of the ecosystem is influenced by what goes on around it, not just in immediate vicinity, but in the greater system surrounding it. This is especially concerning because “the greatest modern threat to biological diversity in Canada...is habitat loss” (Muldoon et al. 2020, from Environmental Law and Policy in Canada).

Removing requirements for recovery strategies and management plans is a great way to ensure that developers do not take responsibility for impacts they have on our natural environment, which has impacts on Ontarians generations to come, and is not simply a temporary trade-off we can make in exchange for poorly or hastily planned development.

Registering a development project does little to help species if the project is not given its fair time to be screened for potential damage. Just because a registration approach is used in other activities that impact the environment, does not mean it is an acceptable or desirable approach here or in general - Canada is still a far way from operating in harmony with its nature. I wonder what will happen to registration-first projects that are later deemed to be harmful. I also wonder how stopping a project mid-development would be considered furthering your goal of accelerating development.

What you are calling simplified and streamlined is actually a gutting of a crucial piece of Ontario’s protective legislation. My peers and I hope you will reconsider the ways in which you plan to upgrade the legislation and instead base it on the actual advice of ecologists and other experts in the biological and environmental fields.