Message sent to my local MPP…

Message sent to my local MPP:

I have no expectation that a politically motivated, ideologically-driven decision will be re-considered by providing facts, but I still feel obliged to point out that your governments assertions about improving outcomes for endangered species ring extremely hollow (unless you consider the development industry to be an endangered species). Suggesting that decisions will be science-based are under-mined by the following:

https://ero.ontario.ca/notice/013-5033

1. ....the proposed changes would provide the Minister with authority to temporarily suspend species and habitat protections for up to three years for some newly-listed species when the following specified criteria are met:

applying the prohibitions to the species would likely have significant social or economic implications for all or parts of Ontario so additional time is required to determine the best approach to protect the species and its habitat;
the temporary suspension will not jeopardize the survival of the species in Ontario; and
one of the following further criteria is met:
the species has a broad distribution in the wild in Ontario;
habitat availability is not a limiting factor for the species;
additional time is needed to address the primary threats to the species, or co-operation with other jurisdictions is necessary to reduce the primary threats to the species,
other criteria that may be specified by regulation.

This totally politicizes the process. Who gets to define a "significant social or economic implication"? Suspending protections for three years would be fine if this also applied to suspending development approvals pending the decision -- this absence is glaring. The bullet "...other criteria that may be specified by regulation" is particularly fishy since it basically allows you to play a wild card at any time in the future to justify a decision to suspend protection.

Having worked in government, my doublespeak radar is instantly triggered by the phrase "scoping of... protections where appropriate". Who gets to decide where this would be appropriate? Despite your attempts to paint this otherwise, this is clearly another means of politicizing the process to allow specific development approvals to proceed.

C. Remove the mandatory legislative requirement and timeline to develop a habitat regulation proposal for each newly-listed threatened or endangered species and retain the option to develop a habitat regulation when needed.

D. Enable the Minister, rather than LGIC, to make species-specific habitat regulations.

Enough said. It doesn't get more political than this.

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 proposed changes would authorize the creation of a regulatory charge that could be paid by persons who are permitted to carry out otherwise prohibited activities under certain permits, agreements, and regulations. The charge would be paid in lieu of fulfilling certain potential conditions that could otherwise have been imposed under the permit, agreement, or regulation. The proposed charges would only be available in respect of species prescribed by regulation. The price for the payment-in-lieu (i.e. regulatory charge) will be within the range of costs that a client would have otherwise incurred through meeting the species-based conditions of an authorization. Clients would still need to fulfill some on-the-ground requirements, including considering reasonable alternatives for their activity and taking steps to minimize the adverse effects of the activity on the species at risk.

This is where your administration really shows its hand. The notion that paying a charge determined by politicians (seriously, how do you determine the cost of meeting species-based conditions of authorization in a situation where there would have been a prohibition on development) will somehow compensate for carrying out prohibited activities is utter nonsense and you must surely know it.

What's notable about your plans to de-fund agencies like Conservation Ontario while supporting the development industry is that nobody buys your propaganda about economic development and the creation of more affordable housing. If this were true it would be occurring within the existing urban footprint. Cutting funding to Conservation Ontario and weakening the ESA suggests that the future development that your government wants to encourage will occur in green field locations. As a constituent who lives in the rural portion of your riding, I would like to point out that there are many others who are deeply concerned about the prospect of paving over natural lands and diminishing the ability of Conservation Authorities to provide programs. There may not be enough of us in the riding to cost you your seat in the next election, but if your other deeply unpopular policies alienate enough of Burlington's urban electorate you will find yourself out of a job come 2022.