I am writing to express my…

ERO number

013-5033

Comment ID

28545

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Individual

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Comment

I am writing to express my extreme opposition to the proposed changes to the Endangered Species Act, 2007. The proposed changes will utterly undermine the important purpose of the Endangered Species Act, which is to protect species at risk and their habitat, and support their recovery in Ontario. Instead, the proposed changes to the Act will lower protection for species and hinder their recovery, while making processes simpler for business and development to impose threats on our natural heritage. As an Ontarian, I cannot stand for this. The proposed changes will have a devastating impact on our species and natural spaces, features that are invaluable and irreplaceable. Biodiversity is, and must be considered as, a valuable asset to Ontarians, yet the proposed changes to the Act do not reflect this fact.

I am particularly concerned with the following proposed changes:

1) Removing automatic protections for listed species, allowing the Minister with authority to suspend prohibitions for species that would likely have significant social or economic implications. This proposed change would target species that commonly intersect with human interest, which are species already at high risk of harm as a result of human impacts. This proposed change will not improve the Endangered Species Act for species at risk, the true intent of the Act, but instead will jeopardize the recovery of vulnerable species.

2) Creating a new landscape agreement that allows authorized persons to execute beneficial actions that may not apply to the species impacted by the authorized activities. This proposed change will be devastating for species that commonly intersect with human interest. What safeguards would exist to ensure certain species are not repeatedly impacted by authorized activities without any beneficial actions taking place to support their recovery?

3) Establishing a Species at Risk Conservation Fund to allow for a “pay to slay” approach to species at risk conservation. Again, this proposed change will have hugely negative impacts for species at risk, while improving the process for business and development, which is not the intent of the Act. Charging a payment-in-lieu within the range of the costs that a client would otherwise incurred through meeting the species-based conditions of an authorization is essentially negligible in relation to the local extirpation of a species or habitat. What methods will be used to assign a price to a species?

The proposed changes to Ontario’s Endangered Species Act come at a time when urgent actions are needed to reverse rapid population declines in our species. This month, the United Nation’s Intergovernmental Science-Policy Platform on the Biodiversity and Ecosystem Services released their assessment indicating that one million species across the world are currently facing extinction largely due to human impact. This panel of 132 government experts clearly and uniformly indicate that biodiversity should be at the top of the global agenda. While this is the most comprehensive assessment of its kind, it is not the first. The State of North America’s Birds report was released in 2016 and clearly indicates that one third of all North American bird species need urgent conservation action due to rampant threats to birds and their habitats. Ontario is not immune to these threats or warnings. However, the proposed changes to the Endangered Species Act DIRECTLY contravene these repeated and evidence-based recommendations. Ontario supports a vast array of species, and it is not too late to act. Rather than removing protections for species from the Endangered Species Act, we need to increase protections and help safeguard our natural heritage from human-mediated threats. This approach would indeed be a modern approach to species conservation, not the approach that the Ontario government is currently proposing.