We are writing to express…

ERO number

013-4143

Comment ID

23247

Commenting on behalf of

Sault Naturalists of Ontario and Michigan

Comment status

Comment approved More about comment statuses

Comment

We are writing to express our concerns with the current 10-year review of the Ontario Endangered Species Act.

The Sault Naturalists Club is a group of about 100 people from all walks of life. The club objectives are to provide members with a common meeting ground for exchanging ideas and for broadening their knowledge and understanding of natural science and to promote the appreciation, preservation, and conservation of our natural heritage. We live in the north and we are well aware of the importance of resource-based industries to the provincial economy.

Our interest in species-at-risk is not a casual one. Members are currently actively doing field work toward the study and protection work for 4 species of threatened turtles, 2 species of dragonflies, and Chimney Swifts. For over 50 years we have contributed to citizen science studies of bird populations and we have recently added reptiles, amphibians and butterflies.

Much of the Endangered Species Act review process appears to be a thinly-veiled attempt to ignore the needs of threatened species while favouring industrial and economic development. Our members support economic development, but not at the cost of further eroding protections for species that are already “on the edge”. There is no reason for economic development and sound environmental stewardship to be mutually exclusive.

Among our concerns:
1) It is imperative that the long list of exemptions for forestry, hydro, mining and commercial development, approved by Cabinet in 2013 be repealed.

2) If scientific bodies such as SARPAC and COSSARO conclude that a species is at risk it is at risk and it needs immediate protection, period. To have politicians deciding whether this really matters, or anything should be done about it is simply absurd. It also blatantly contradicts the first stated outcome of this review, to “Enable positive outcomes for species at risk”.

3) Removing or extending timelines for planning and reporting of mitigating activities would absolutely work against the species at risk. Without timelines planning is meaningless, and without reporting how are the people of Ontario to know that appropriate actions are being taken?

4) Allowing industries or developers to simply pay money in to a fund in lieu of protecting the species-at-risk is again, simply absurd. Species at risk do not need money in a bank account; they need protection on the ground. To allow these payments would certainly speak of a government that lacks both common sense and even the most basic understanding of natural processes.

5) While it may seem intuitive that streamlining environmental legislation and related guidelines will increase industrial productivity, this is certainly not the case. These policies not only protect biodiversity but also enhance the image of Ontario industrial products with respect to Sustainable Development. Regressing on these policies can negatively affect environmental certification of Ontario products leading to loss of markets and subsequent negative impacts for industrial profits and employment.

In conclusion, we ask that your government renew Ontario’s commitment to sustainable development of all industrial products by maintaining and enhancing environmental legislation to ensure the protection of biodiversity and economic prosperity of this province for present and future generations.

Thank you for your attention

President, Sault Naturalist of Ontario and MIchigan