Nature and biodiversity is…

Nature and biodiversity is in decline worldwide. An estimated one million species of plants and animals facing extinction.

We need to INCREASE not decrease protections for species at risk. We need to enforce the government to accountability and speedy action to identify and protect species and their habitats. We need to severely limit exemptions provided to industry and other stakeholders that allow them to skirt the protections.

I do not support de-coupling the listing process from automatic protections and providing greater Minister’s discretion on protections, while keeping the assessment as a science-based process at arm’s length.

This would allow the minister to disregard recommendations by experts, and put economic or other concerns ahead of the species in need of assistance.

I do not support the allowance that “the temporary suspension will not jeopardize the survival of the species in Ontario” because this does not provide a holistic view of a species’ chances of survival. Provincial geographic boundaries are a human construct and should not be taken into account where species survival is concerned.

- I do not support removing 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.

This is because the government needs to be held accountable to implementing corrective action in a reasonable time frame. It also removes the people’s ability to hold the government accountable in court if there are no hard requirements that they are required to follow. In fact, I believe the timelines should be shortened.

I do not support enabling the Minister, rather than LGIC, to make species-specific habitat regulations, because this should not be a political process.

I do not support extending 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 SAROList). This allows the government to unnecessary delay action.

I do not support requiring COSSARO to consider a species’ condition around its broader biologically relevant geographic area, 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.

‘Relevance’ of a species should NOT be part of the equation. Biodiversity is essential to ecosystems and human beings should not be allowed to make value judgements about what species are relevant or not. We are horrible at predicting unintended consequences and should not be playing god in this manner.

“Recovery strategies are advice to government, and that Government Response Statements are the government’s policy direction for species at risk.”

Politicians and the government should not be making these decisions. Scientists should.

“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.”

RICH CORPORATIONS OR INDIVIDUALS SHOULD NOT IN ANY CIRCUMSTANCES BE ALLOWED TO PAY TO EXEMPT THEM FROM THE LAW.