Thank you for the…

Thank you for the opportunity to comment. I copy these points from the previous website and comment on each in particular.

On proposed change A: ...Also, extend the time from when a COSSARO report is received by the Minister to when listing is to occur from three to twelve months (i.e., when a species must be added to the SARO List).

I think this will have the effect of negating a lot of the value of protecting species at risk, because it gives operators 9 more months in which to clear the land they are interested in of the species to be regulated. Where I live this is very common: wetlands are being declared significant, so they are drained as rapidly as possible before the regulations take effect. Same thing: destroy the regulateable area or species before the regulations to protect them come into force. This change simply enables such activity. One cannot and should not pretend it does not occur.

E: Require COSSARO to consider a species’ condition around its broader biologically relevant geographic area, inside and outside Ontario, before classifying a species as endangered or threatened. If the overall condition of risk to the species in the broader biologically relevant geographic area is lower, COSSARO would be required to adjust the species’ classification to reflect its overall condition.

This is biologically naive. Organisms adapt to their surroundings, and local populations have genetic specialties allowing them to survive. Just because a species is common in the United States, doesn't mean the genetics of that population would allow it to survive in Ontario and re-populate it when the time comes. Population fragmentation is also a concern -- if we do not attempt to keep a species across its entire geographic range, we increase the population fragmentation and increase the chance that populations elsewhere will be harmed. Finally -- all species have a role to play. A species that is present elsewhere but extirpated in Ontario cannot play its ecological role in Ontario. What these roles are run from primary producer to primary consumer, and organic recyclers. How many ecological specialists is the province content on losing, as it accepts the loss of species from Ontario?

F. Broaden COSSARO member qualifications to include members who have relevant expertise in ecology, wildlife management, as well as those with community knowledge.

Is the province going to accept biologists and ecologists on economic boards? What about plumbers and taxi drivers into the regional health boards? What is 'community knowledge' and why is it relevant? This is simply an attempt to bring non-science into scientific decision-making. If the government wishes to overrule COSSARO's scientific advice when making policy, then be transparent about it. Over-ruling it by introducing non-science into the actual advice-making is not transparent, and is not justifiable. This proposal should be deleted.

Section 4 "Creation of Regulatory Charge and Agency": Ontario is also proposing to create Canada’s first independent Crown agency proposed to be called the Species at Risk Conservation Trust, to allow municipalities or other infrastructure developers the option to pay a charge in lieu of completing certain on-the-ground activities required by the act. The funds would support strategic, coordinated and large-scale actions that assist in the protection and recovery of species at risk.

The major concern here is that money is not what species at risk need. They need habitat protection, they need regulatory protection. Recovery strategies could benefit from money, but recovery is a last resort, and protection of habitat is much more efficient and less costly. To allow actors that wish to destroy habitat to pay their way out is not a deterrent to those seeking this 'out'. Their costs are simply passed on to their clients / consumers of their products. It makes no difference to them, and I predict there will be many requests to simply buy one's way out of habitat protection. The money is not going to have the desired outcome regarding species retention on the landscape. Not to mention that so much of the money will simply go to overhead for this new independent Agency, and not at all to species recovery, research or any useful activity in support of conservation. This amendment should be deleted.

"Additional changes related to issuing permits", part C: Provide a new transition provision for existing Endangered Species Act permit- and agreement-holders to continue to operate for twelve months following the application of new species or habitat protections while they seek amendments to their permit or agreement to address newly listed species. Currently, existing holders would, upon the species being listed and protected, need to stop their activity that impact the species or its habitat and wait for their permit or agreement to be amended.

Here I can make the same comment as earlier: this only provides for a longer 'destroy while you still can' time, and to believe it will not be abused is to be naive. Already we see far too many instances of 'act first, apologise later'. This amendment only supports such thinking, and will not in any way improve protections for species.

Ditto, Part E:Create a new landscape agreement that takes a strategic, coordinated and consolidated approach to authorizing clients undertaking multiple activities, and which could allow for limited conservation banking to achieve positive outcomes for species. The issuance of a landscape agreement would be dependent on conditions, including:
the agreement requires reasonable steps to minimize adverse effects of the authorized activities on the impacted species under the agreement,
the agreement requires actions to benefit one or more species,
reasonable alternatives have been considered, including those that would not adversely affect the species specified in the agreement, and
the beneficial actions required by the agreement outweigh the adverse effects to the impacted species under the agreement.

Here I don't understand the use of the word 'considered' -- to consider is to do nothing. It is not binding, it is not useful. To require 'reasonable alternatives to be considered' is an empty statement. The alternative that would not adversely affect the species should be the one *chosen*, not just *considered*.

Since I was born, the number of birds, that is, their population size, not the number of species, has dropped by two-thirds. That is equivalent to a human population loss in Ontario of 6.6 million people. Only twenty years ago, I still needed to use the window-washing station at the gas pumps when I drove at night in the country, due to the accumulated insects on my windscreen. Not any longer. I used to have bats in the barn. Swallows too, and on the power lines. I used to hear frogs in the spring. I live outside of Ottawa, in a rural area. We have allowed the loss of so much already, all in the name of 'balance'. The balance sheet is so far out of whack, any talk of 'balance' is naive. We will continue to lose species no matter what we do, but the proposed amendments here will speed that process up, and enable individual companies to profit even more from the public good -- nature and all that lives in it. I think the changes you propose are not in keeping with conservation philosophy, with biological reality, nor does it cast a critical-enough eye on the natural activities of business interests. Regulations exist to uphold certain standards, and are not just 'red tape'. Smart regulatory design is good. Loose regulatory design that allows for loopholes, stacking of advisory bodies with non-specialists to hide pertinent advice from Ministers, and removal of protections for species across their range is not good, not productive, and counter-intuitive.

Thank you for the opportunity to comment.