I am writing to you to…

I am writing to you to express my deep concern regarding the proposed amendments to the Endangered Species Act (ESA) and Environmental Bill of Rights (EBR) regulations. The Progressive Conservative government appears to care more about short-term gain than safeguarding our province's biodiversity and the environment which all Ontarians depend on.

The ESA exists to protect and recover species facing extinction in Ontario; it is already weak and allows harm to be caused to species at risk. The Progressive Conservation government is wasting an opportunity to strengthen its implementation by proposing these changes during its 10-year review.

The EBR exists to protect the environmental rights of Ontarians and enable us to participate in environmental decision-making. By taking our right to be notified and participate in decisions to remove, reduce or pause protection for endangered and threatened species, you are undermining the value we place on our environment. This is unacceptable.

Specifically, I oppose the following amendments presented in this posting:

1. A) Extending the timeline between the Ministry receiving a COSSARO report and legal listing of assessed species from 3 months to 12 months;
D) Allowing the Minister to require COSSARO to reconsider the classification of a species where the Minister forms the opinion based on scientific information that the classification is no longer appropriate;
E) Requiring COSSARO to adjust a species' classification to reflect its overall condition across all jurisdictions if it exists beyond Ontario;

2. A) Decoupling the listing process from automatic protection, allowing the Minister to suspend the protection that should be afforded to threatened and endangered species;
B) Limiting species protection via "scoping" with the Minister's discretion;
C) Removing the mandatory legislative requirement and timeline to develop a habitat regulation proposal for each newly-listed threatened or endangered species;
D) Enabling the Minister, rather than LGIC, to make species-specific habitat regulations;

3. A) Giving the Minister discretion to extend the 9-month Government Response Statement development timeline for some species;
C) Allowing the Minister to extend timelines for conducting the review of progress towards protection and recovery based on individual species’ needs;
D) Removing specific reference to posting under the Environmental Bill of Rights, 1993 and instead requiring that certain products under the Act be made available publicly on a government website;

4. Creating the Species At Risk Conservation Trust, and the regulatory charge that applicants seeking to destroy species at risk habitat will pay;
A) Removing the requirement for the Minister to consult with an independent expert in the ‘D’ permit process and replacing the requirement for LGIC approval with Minister approval;
B) Broadening the approach to minimize adverse effects for permits and agreements to ignore risk to individuals rather than whole species at risk;
C) Providing 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;
E) Creating a new landscape agreement for clients to use to destroy species at risk habitat;
F) Weakening the test for a s. 18 provision;
G) Removing the requirement for the Minister to consult with an expert if the Minister forms the opinion that a proposed regulation is likely to jeopardize the survival of the species in Ontario or to have any other significant adverse effect on the species.

I oppose any amendment to the EBR that reduces our rights to be notified or consulted with for any environmental decision-making.

Clearly these amendments serve to open up species at risk habitat to development and destruction, and remove protections of the imperiled species themselves so that special interests will not be punished for killing them. There are also serious and transparent attempts to undermine science as part of the listing and protections process in these amendments.

I urge you to abandon the above amendments and strengthen the implementation of the ESA in the following ways:

A) Repeal the exemptions created in 2013 to permit forestry, hydro and mining industries to conduct activities that negatively impact species at risk;
B) Repeal the exemption created in 2016 to allow hunting and trapping of the threatened Algonquin wolf;
C) Amend section 57 (1)1 of the ESA so that exemptions will only be allowed if they do not jeopardize the survival and/or recovery of endangered and threatened species;
D) Amend the ESA so that all permits that allow habitat or species destruction pass the overall benefit test, and are monitored and enforced to ensure the benefits support species at risk recoveries.

Protecting Ontario's endangered species is vital to the future of our province's biodiversity, the health of our environment, and the ecosystem services which all Ontarians rely on. I feel very strongly about this issue and that the new proposals that are being made to these acts are so detrimental to our environment . I will be monitoring this important issue closely.