Thank you for the…

Thank you for the opportunity to comment on the Ontario government’s Review of Ontario’s Endangered Species Act (ESA).

The ESA is intended to safeguard endangered species. As such, the ESA must accord top priority to the needs of species at risk. I accept that effective efforts to conserve species are challenging – scientifically, ethically, and economically. However, all who are alive today have an ethical and practical responsibility to conserve the web of life which underpins our well-being, our security, and our survival. Given this truth, I vehemently oppose the crass attitude, the tacit objectives, and the proposed changes put forth in your ten-year review of the ESA.

Today we witness a human-induced biological crisis: global mass extinction of species at 1000 to 10,000 times the evolutionary baseline. Yes – worldwide, and even in Canada, wildlife is in alarming decline. I urge you to fortify the ESA according to the insights, concerns, and solutions put forth by countless conservation experts: scientists, technicians, and organizations. Moreover, I urge you to support the ESA with the necessary clout: power, funding, and staff.
- Reinstate the ESA, as legislated in 2007.
- Eliminate the changes of 2013 that introduced exemptions for certain industries and broad regulations to permit diverse destructive activities (that could entail killing, harming, harassing, capturing, taking, possessing, selling, trading species, as well as degrading and destroying habitat), and to accept intent to minimize harm rather than require precluding and compensating for harm.
- Reinforce science (objective evidence, logic, and critical thinking) as the cornerstone of the ESA:
1) science-based listing of species at risk (including Indigenous Traditional Knowledge),
2) mandatory protection of threatened and endangered species and their habitats, and
3) legislated timelines for science-based survival and recovery plans, actions, and reporting.
- DO NOT politicize the ESA by giving the minister the power to remove or delay species protections.
- We must use the precautionary principle – err in favour of conservation! Protecting species at risk and their habitats must be automatic, immediate, and not subject to the whims and discretion of the minister or the influence of lobbyists.
- Protect existing species and habitats. Substituting this with payments to a conservation fund is an inadequate, unacceptable alternative because we have no known, effective way of recreating natural capital.
- Landscape-level authorizations for harmful activities increase risk for vulnerable species because it eliminates opportunity to discover or address site and species-specific concerns.
- Reinstate and provide copious support to the Environmental Commissioner of Ontario. How else can we confirm that our actions are effective and match our intent? Our survival depends on this.
Though the Ontario government claims that it wants to improve protections for species at risk, the options under consideration would clearly make it easier for industry and development proponents to damage or destroy the habitats of species that get in the way of business. Endangered species are not a bureaucratic burden that impede economic development. Good grief! Our very lives depend on the vulnerable diversity of species that blesses Ontario today. We have moral and practical obligation to effectively stewarding this web of life. This obligation critically outweighs the supposed value of maximizing short-term economic opportunities for anyone alive today. As noted by Ecojustice …
Intact ecosystems regulate our climate, pollinate our food, enrich our soil, underpin the processes that provide clean air, water and land that we need to survive. Natural systems are critical drivers of the economy, supporting vital industries like forestry, fishing, and tourism. Species are the engine that keep these natural systems running.

As stated in 2013 by Gordon Miller, the success of the ESA ultimately relies on effective, consistent, and transparent implementation in line with the intent and purpose of the Act.

Poor implementation of the ESA is the problem – not the law itself. Invest in planning, communications, program development, and staffing. Do not consider, let alone proceed with environmental deregulation.

I hold you accountable for protecting the long-term interests of all Ontarians – human and otherwise.