Comment
Eliminate the clause for Significant social or economic benefit permit, s. 17(2)(d): A significant social or economic benefit permit may be issued for an activity that will result in a significant social or economic benefit to Ontario, but the activity would have impacts that are otherwise prohibited under the Act. There is too much ambiguity in this and it can easily be abused. What is the definition of significant social benefit? Who decides this? I can't agree that the idea of trading SAR protections because of a vague promise of social or economic benefit is in the spirit of conservation or in the spirit of the species at risk act. This clause undermines the whole purpose of the act and allows profit hungry businesses skirt the law. Maybe instead provide incentive for business models that aren't damaging to habitats.
Also it would be beneficial to many meadow dwelling species of birds that are currently listed as species at risk (I'm thinking Bobolink, Eastern Meadowlark, etc) if we implemented more regulation to farmers as to when they can plow their fields. They're literally destroying nesting and breeding bird territory DURING breeding season, and no one does anything about it because farmers are such a protected group of people. If we provide more oversight on these environmentally unsound farming practices, we might be able to help mitigate some of the massive ecological damage farmers cause (without even touching on how important it is to subsidize the diversification of crops).
Area of focus 3 also is troubling for me because I envision deadlines extended and extended and extended until it is too far gone to make any meaningful changes.
Submitted March 3, 2019 2:49 PM
Comment on
10th Year Review of Ontario’s Endangered Species Act: Discussion Paper
ERO number
013-4143
Comment ID
23280
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Comment status