I am a member of Safe Wings…

I am a member of Safe Wings Ottawa, a voluntary organization whose mandate is the prevention, research and rescue of birds that collide with windows. Most of the 250 000 birds that collide each year in Ottawa alone (the majority die on impact) are migratory birds, including Species at Risk. I care deeply about birds and the continued existence of all living species (mammals included), who already face innumerable challenges to survive given the negative impacts humans are causing on their habitat, food sources, movement, etc.

It is beyond comprehension that the very Ministry whose raison d’être is conservation and the environment would propose this legislation which treats species at risk as red tape and goes as far as reducing their protection to only their dwelling place or nest and immediate surroundings. Economic growth is NOT your mandate. With diluting protections this much, who is left in the province to look after species interests? Do you really think walking away from provincial protection of SARA species will have no impact on these species? Federal laws do NOT protect habitat for migratory birds on private or provincial crown land, as you incorrectly suggest. With your new proposed approach, it won’t be long before the piping plover, prothonotary warbler and red-headed woodpecker numbers dwindle even more.

This legislation removes the only regulatory tools you had to protect the habitat where threatened and endangered birds nest and feed. Not only that, you are offloading habitat protection to the voluntary sector on both private and provincial lands. Too convenient!

The new ESA is a significant step backwards for bird conservation in Ontario. Its economic growth emphasis means new development will be even less likely to avoid impacts to species and the natural areas they absolutely depend on. This is happening at a juncture in our history where the forests, wetlands and grasslands birds depend on need to be protected for future generations and climate change mitigation.

The proposed changes also eliminate the requirement to develop recovery plans and propose no meaningful alternative. Without recovery plans, the new Species Conservation Program will not be able to set priorities and stakeholders will not have guidance on the most important places to protect and actions to take.

I strongly believe Ontario should protect habitat for migratory birds and that you should reverse course. The existing habitat definition and protections of the ESA should be retained. They provide a clear approach to conserving Ontario’s most at-risk birds, and any issues with delays or lack of clarity can be dealt with through process improvements.

At a bare minimum, legal protection for threatened and endangered birds should continue to exist for habitat on provincial Crown land (like SARA protections apply on federal Crown land).

Finally, it is completely unacceptable to give political representatives discretionary powers over which species are added or removed from the protected list. Political considerations should never factor in such decisions, only scientific or subject-matter expert ones.