As a constituent of the…

As a constituent of the Ontario government, I take issue with the suggestions in this review. The Endangered Species Act was created for the purpose of protecting the threatened, endangered, or otherwise at risk wildlife of Ontario. It was not created to see how far businesses could push the boundaries of habitat protection in the name of "economic development".

Here are the particulars of the review that I, as a member of the body which the government is supposed to represent, do not agree to:

First, I do not agree with the suggestion of an alternative to automatic species protection, nor the further proposal of "ministerial discretion on whether to apply, remove or temporarily delay protections for a threatened or endangered species, or its habitat." This sounds too much like making room for businesses to encroach on the protections of both land and species by removing their threatened or endangered classification.

Secondly, I do not agree with the suggestion of requesting " an additional review and assessment in cases where there is emerging science or conflicting information." This is in direct conflict with the opening preamble of the Endangered Species Act:

"The United Nations Convention on Biological Diversity takes note of the precautionary principle, which, as described in the Convention, states that, where there is a threat of significant reduction or loss of biological diversity, lack of full scientific certainty should not be used as a reason for postponing measures to avoid or minimize such a threat." - The Endangered Species Act, 2007

Thirdly, the assertion that habitat regulation is not needed because of general habitat protection. Habitat regulation, in the Endangered Species Act, outlines a) specific boundaries of the [habitat], b) describes features in that [habitat] and c) describes the [habitat] in any other manner. The removal of these details would allow for boundary ambiguity of what businesses can and cannot infringe upon. As put in the review: "improve certainty for businesses and others about the scope of habitat that is protected." The Endangered Species Act is meant to determine what we should prioritize in protecting, not how much we're allowed to destroy.

Finally, in "Area of Focus 4", the challenges and discussion questions can be interpreted as looking for permission to create ways or loopholes for businesses to speed up their developments on protected lands. The review mentions "the requirements that applicants must fulfil to obtain an authorization can be extensive, creating barriers to economic development." What the review calls a challenge, I would call the entire purpose of the Endangered Species Act: to create barriers to economic development to protect those who cannot protect themselves.

The Endangered Species Act is not an invitation for the current government to create loopholes for economic development, and yet this review seems to imply just that. As a member of the government's constituency, I am not happy with their constant attempts to undermine the environmental protections we already have in place for the benefit of businesses (e.g the Bill 66 fiasco). Businesses will come and go, and to cater to an ephemeral customer at the cost of our environmental health and it's species is not only unwise, but it is also morally wrong. I know that environmental protection isn't easy, and will require sacrifices. But just because the right thing isn't easy, doesn't mean it's not right.