Comment
I have been advised that the current Endangered Species Act is having a negative impact on the forestry industry due to the existing guidelines, conditions, etc. In recent years there appears to have been a move to lessen some of these guidelines. It is my opinion that any move to decrease the guidelines will have a very severe impact on Endangered Species in Ontario. The forest Industry is suggesting a short time period for habitat protection (turtle nesting and snake wintering sites). This would reduce habitat protection not enhance it.
Recently the MNRF has introduced a guideline entitled "Forest Management Guide for Conserving Biodiversity at the Stand and Site Scales". In my opinion this document offers less protection for Species at Risk and their habitat. I was told that the amendments were science based however it appears more likely that economics has trumped science once again.
One of the glaring failures in the current Act is the lack of project oversight and compliance to the Act. In my experience there appears to be very few warnings, charges and prosecutions of violations of the Act. This may be a staffing or training issue. The public has become very aware of the need to protect these rare and endangered species and the need to enhance the protection of the spcies and their habitat.
Here are some examples of compliance failures that I have observed;
In preparation for the realigning of Highway 69 MTO hired a consultant to conduct Whip Poor Will surveys. These surveys were not conducted in compliance to existing guidelines. Some of the surveys were conducted during the wrong timeframes. Some surveys were conducted on right of ways that had been cleared of all vegetation. How can we have any confidence in surveys that are so poorly conducted. Did anyone follow up with MTO?
As part of the same project the MNRF issued a license to MTO regarding Species at Risk. MTO Contract employees received training on species identification and handling. In spite of the training there were violations of the terms and conditions of the Permit issued by MNRF. Reptiles were moved outside of their local habitat. When MNRF was made aware of these violations the MNRF response was that would discuss the issue with MTO at their next annual meeting. No investigation, no warning, no followup, nothing?
During one phase of this project MOECC staff investigated over 30+ environmental spills. These spills included release of deleterious materials into watersheds, streams, rivers, sensitive wetlands, etc. Some of these violations were reported to DFO, DFO did not investigate or send any compliance staff to investigate the potential negative impacts to the habitat, the Species at Risk the natural environment, etc.
During the construction of the two bridges at the Murdock River, the MTO contractors repeated exceeded the MOECC Blasting Guidelines. The records of these blasts was shared with MOECC staff and nothing was done, no investigations, no warnings, nothing. The Murdock River is habitat for many Species some of which are Endangered. How can the public have any faith in the process if there is no compliance or reprimand to the violators?
Our previous Premier stated that polluters would be held responsible for their decisions. It is time to put those words into action.
In closing I would offer the words of Albert Einstein "Nothing is more destructive of respect for the government and the law of the land than passing laws which cannot be enforced."
Submitted February 22, 2019 1:56 PM
Comment on
10th Year Review of Ontario’s Endangered Species Act: Discussion Paper
ERO number
013-4143
Comment ID
21948
Commenting on behalf of
Comment status