I oppose the changes…

I oppose the changes proposed in the new Species Conservation Act (SCA) in the strongest terms possible. These changes show the government has zero interest in actually protecting any form of biodiversity in the province, despite abundant evidence that shows the financial benefits of biodiversity (e.g., see https://test.ero.ontario.ca/public/public_uploads/2019-10/296833.pdf; https://albertawilderness.ca/wp-content/uploads/2016/03/20091100_rp_nat…; https://davidsuzuki.org/science-learning-centre-article/ontarios-wealth…) never mind our ethical obligations to not destroy species. True conservation requires more than just administrative efficiency. Can certain items be streamlined? Yes. Does the SCA do that appropriately? Emphatically and categorically, no it absolutely does not.

To remove the goal of species recovery is simply lunacy. These are the species that have already lost too many individuals, yet the government is satisfied with their current degraded state, not even pretending anymore that we should be trying to increase their populations. To have a government state that the status quo of declining diversity and abundance is their goal is appalling. There is no reason to make this change.

The government utterly fails to understand that species need more than just a ‘core area’ to survive. For example, the SCA mandates that vascular plants only need a ‘critical root zone’ as their habitat. This is just so ridiculous that I almost can’t believe it’s actually proposed. Does the government really thing that paving around the roots of an endangered tree is sufficient to even conserve individuals of that species? The government claims these changes are necessary because the current definition of habitat “includes broad areas beyond core species protections”. Guess what? It includes broad areas because these areas are necessary for species to survive. How does the government not grasp this concept? The fact that the government explicitly says only “core” areas are necessary is so obviously wrong that it defies logic. Have they even talked to biologists? The government should NOT be allowed to justify its actions based on fundamentally wrong assumptions about how species and communities function.

The new SCA no longer even pretends to use science to determine the listing of species. This is wrong, and the government must keep the current legislation’s requirement to follow COSSARO’s recommendations to list species; this must not be left to the political and economic whim of the government. You do not get to decide which species are worthy of protection based on whether they’re an inconvenience to your plans to pave over this province. You can both protect and recover species, and have development; this is not a dichotomous choice, no matter how often you portray it this way to justify your short-sighted actions.

I was very puzzled by the statement that the SCA will “strengthen our ability to enforce species protection laws to ensure that all proponents comply with the rules and expectations of this new approach”. Last I read, the MECP/MNRF had not inspected a single project between 2007 to 2020 for compliance (https://www.auditor.on.ca/en/content/annualreports/arreports/en23/1-23F…). So why would I believe the government would start doing this now? The SCA is also trying to use a retroactive approach – removing the ability to conserve species up front, and instead claiming they will penalize the harm of species after it has happened – which looks better for the government because it’s easier to get press for fines/convictions than it is for species recovery, but is quite obviously worse for the species at risk. Making changes that allow the government to pat itself on the back for handing out fines, while ensuring that species continue to decline, is an underhanded move and must not happen.

The Ontario government purports to be all about activities that are unique to Ontario. The name of the new bill says it all: Protect Ontario by Unleashing our Economy Act, 2025 (Bill 5). In reality, they want to ‘protect’ Ontario’s economy at the expense of Ontario’s biodiversity. They fail to understand that the functioning of each stream, watershed, forest, meadow, and wetland is dependent on the species present in it. The Rouge River doesn’t care that redside dace still exist in the United States; it functions differently as soon as that species is lost. I function differently, too. I am sadder, poorer (emotionally and financially), and we are leaving an impoverished legacy for future generations. You can build smarter, and be smarter, without eliminating protections and recovery for declining species. This new Act must not pass.