I am professional ecologist,…

I am professional ecologist, and have worked as a researcher and planner on more than 200 projects involving ecological management in Ontario.

Throughout my 10 years of experience, the Endangered Species Act has provided a framework for meaningful long-term management of our most threatened species.

The proposal to gut this act is deeply worrying. And this gutting would greatly limit our ability to properly manage and sustain many declining wildlife species that are ecologically, economically and culturally significant to Ontario and Canada.

Furthermore, endangered species represent the overall quality of the ecosystems they inhabit. Their management should be considered a crucial part of protecting the fundamental water, air and soil systems that we all depend on.

The most troubling proposed changes to act are listed below and my rebuttal is provided:
1. Species listed as threatened or endangered may no longer be automatically protected

This would mean that many species in need of immediate attention and management, would experience a purgatory of the "protection approvals process", wherein major harm and declines may occur completely unnecessarily. Secondly, this would undoubtedly lead to disposal of all scientific, and expert information in favour of political advantage for any given species at risk.

2. Changes to “edge of range” species means considering populations outside of Ontario when listing a species at risk. This includes many Southern Ontarian species, allowing Ontario to simply opt out of protecting species at home.

Ontario is not an "edge of range", it is a full and important part of the range for many ecologically important and endangered species - especially in our carolinian zone. These carolinian Ontario species are quite often found nowhere else in Canada. And, despite representing a small areal percentage of our entire country (~1%), the carolinian zone in Ontario is larger than Souther Korea - or roughly the size of the entire nation of Iceland ~100,000 ha: which can not, in any way, be considered a "small" or "insignificant" area for endangered species management.

In addition to our southern "edge of range" representing a vast area, it also represents a very significant part of the global range for many of the species that occur there, and a very significant part of Ontario's overall biodiversity. Lastly, we can not take for granted that these species will be properly managed internationally and therefore "not our problem". We MUST to continue to endeavour to manage these unique species in our own province - and our own country.

3. Introducing pay-to-proceed system on harmful activities. Developers and proponents should not be allowed to pay their way out of protecting endangered species’ habitats.

It is absolutely wrongheaded to assume that every project, regardless of its costs or impacts, is good for Ontario. Costs and impacts quite often outweigh benefits to the people of Ontario, and an analysis of the impacts to endangered and rare species is an important part of the impact assessment and cost-benefit analysis for any project.

This change would be devastating to our shared ecological systems. Payment would not - could not - be sufficiently charged or collected to undo the damage of certain types of projects barging forward in certain types of locations. This loophole must not be opened.

4. Opening the scientific committee to non-scientist members. This change could allow people with no knowledge or scientific background to be involved in decisions for species.

This is so obviously an indecent part of the proposal that it seems ridiculous to me to need to speak to it. If non-experts intervene in rocket launches - rockets explode. If non-experts intervene in bridge construction - bridges collapse. In non-experts intervene in judicial decision-making - lives are unnecessarily ruined behind bars. If non-experts intervene in healthcare - people stay sick, or get sicker.

For ecological protection, the damage that is done, is chronic and has a time lag but is every bit as real and damaging as the situations I describe above. After a poor ecological management decision due to non-expert interference, people don't typically die the following afternoon in a fiery explosion. However people will be harmed in many tangible ways. Degradation of our ecological systems, means that our air, water and soil (all clearly fundamentally important and irreplaceable) are of poorer quality. Agricultural pests increase. Climate change is exacerbated. Flooding risk increases due to wetland loss. Wildfire risk increases. Invasive species, which often causing massive damage to fisheries, forestry, agriculture, parks, hunting etc. proliferate.

And at the end of the day, quality of life for all people in Ontario decreases. Endangered species management is a critical link in the chain of proper ecological management. Non-experts should have absolutely no ability to interfere with the process, just as surely as they must be barred from their opinions on how to build a bridge.

5. Giving the Minister the discretion to interfere with the listing of at risk species, bringing politics into the protection of endangered species.

This is simply another catch-all way that these proposed changes gut the legislation and increase access for non-experts to interfere in potentially very harmful, costly, and quality-of-life-diminishing ways. Keep the corrupting desire for power (i.e. being re-elected), or money (for your investments, your friends, your own companies etc.) from supporting a harmful project far away from our shared environmental system.

In conclusion - these proposed changes are deeply disturbing. They completely ignore the vast costs of poor environmental management and assume that someone else will pay these costs in the future - while profits are streamlined from detrimental projects being pushed forward in the present.

The changes attempt to bypass a critical part of an effective and meaningful planning process.

Endangered species are not simply rare creatures with negligible aesthetic value. They represent the quality of the ecosystems that they inhabit: which in turn represents the quality of the crucial ecological services that we all require to live (water, air and soil systems).