Re: 10th year review of the…

Re: 10th year review of the Endangered Species Act

I grew up on a small farm in southern Ontario. For the past five years, I have been studying the rare and endangered plant species of southern Ontario’s forests and talking to the landowners who own these forests. I am very concerned that the current review and proposed changes to the Endangered Species Act will counteract the very reason the Act was enacted: to promote recovery of species that are in danger of being extirpated from Ontario.

From the Act itself:
The purposes of this Act are:
1. To identify species at risk based on the best available scientific information, including information obtained from community knowledge and aboriginal traditional knowledge.
2. To protect species that are at risk and their habitats, and to promote the recovery of species that are at risk.
3. To promote stewardship activities to assist in the protection and recovery of species that are at risk. 2007, c. 6, s. 1.

My main concerns are as follows:

(1) Species listed as endangered or threatened by COSSARO are already in great danger of becoming extirpated. In NO circumstances would these species benefit from extending the timeline for the development of Recovery Strategies and Government Response Statements. From the Act: “A species shall be classified as an endangered species if it lives in the wild in Ontario but is facing imminent extinction or extirpation.” These species cannot wait for action. Lengthening or doing away with timelines would be counter to the purpose of the Act.

(2) The plants that I study live in the highly reduced and fragmented forests of southern Ontario. This landscape was once over 80% forested, but now in some counties less than 10% of the land area is forested. For those species with only a few populations left, protecting the forests in which they live is necessary to prevent their extinction. Any activity that would result in the destruction of their habitat results in further losses and prevents recovery. Not providing automatic protections to threatened and endangered species and their habitat would make the Act completely ineffective.

(3) The 2013 exemptions to the Act’s permit requirements have already weakened habitat protections and allowed a proliferation of authorizations to harm the species the Act was meant to protect, as reported in the Environmental Commissioner of Ontario’s 2017 Environmental Protection Report. Further weakening of authorization requirements will only lead to worse outcomes for species at risk. In order to protect species at risk, development that threatens them and their habitat must be prevented, not facilitated.

(4) The plants and animals that have lived in Ontario for thousands of years are unique parts of our Natural Heritage. Most landowners I interviewed in southern Ontario say they value species at risk, and agree that regulations are necessary to help protect them. In a survey of 1,000 Canadians, 89% agreed that it is important to prevent the extinction of wild plants and animals in Canada, and 80% agreed with the need to limit industrial activities in certain areas in order to protect endangered species (see web link).