I'm writing to share my…

I'm writing to share my concern over the measures proposed by the SCA. They remove valuable safeguards, endanger environments relied upon by human and animal residents alike, and prioritize development versus balancing the needs of industry and community.

Under the changes promised by Bill 5, Ontario may override the independent body that currently decides what species will be protected (COSSARO) Under both the amended ESA and the SCA, Ontario is removing the existing requirement for any species identified by COSSARO as a Species at Risk to be added to the protection regulation (and its successor regulation under the SCA) and then be given protections.

The government of Ontario will now have full discretion to choose whether to add any species to the protection list.

So, even if a species was identified by COSSARO as being an extinction risk, the government of Ontario may now decide to not protect it. No guidelines have been provided for how the Province may exercise this power.

This is a concerning amendment that shifts decision-making away from an independent body, and gives the final decision to politicians, who can be swayed by industry lobbying.

The ESA currently defines the “habitat” of an animal as “an area on which the species depends, directly or indirectly, to carry on its life processes, including life processes such as reproduction, rearing, hibernation, migration or feeding.” This protects both the “dwelling place” of the animal, and also the area which the animal depends for other purposes.

Under the amended ESA and the SCA, the only part of an animal’s habitat that will now be protected is the den or the nest – where it sleeps. All the other areas that animals need to live, such as breeding grounds, migratory routes, or areas essential for its sustenance, will no longer be protected.

As humans, we adjust slowly to change - a wider road, a tower infill, a shift from residential to industrial zoning, or even a new bike lane are all met with outcry - which is why we have regulatory measures to ensure all affected parties can be heard and their needs taken into account. Animals, who cannot advocate in the same ways, deserve the same duty of care.

Disturbingly, under the amended ESA and the SCA, the “harassment” of a protected species is no longer a prohibited act. This means that if an action impacts an area in a way which disrupts the normal behaviour of a Species at Risk, that harassment will no longer be an infraction of the ESA.

This change, combined with reducing the types of protected habitat, means that animals will have little protection from stressful disturbances. Over time, stress will cause vulnerable species' populations to drop further.

Ontario is a beautiful place, filled with strong communities. As one of its governing bodies, it is your responsibility to ensure that these communities - both human and animal - continue to thrive.

Many of the ESA's measures make Ontario healthier, stronger, and more resilient. Please don't walk back proven success for short-term economic booms at best.