As a professional working in…

As a professional working in the field of environmental conservation, working directly with species at risk approvals, and as a Ph.D. in Ecology, I directly oppose the proposed changes to the Endangered Species Act. I have selected a few key points to address below.

“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.”

Ontario is at the northern end of the range limits for many species assessed under the Endangered Species Act. Individuals of a species at the limits of their ranges are uniquely positioned to develop adaptations to the extremes of their climate and habitat requirements, potentially allowing range expansion into new geographic areas or climates. It has been demonstrated over and over that climate change is forcing species to either move with the changing climate or perish – with the increase in temperature this most often required species to expand range limits north to maintain the climate conditions in which they can survive. De-listing species at the northern edge of their range limit simply because there are more of them outside Ontario is missing the larger picture of the species requirements, and is short-sighted in that it is hampering the ability of species to adapt to future environments, and therefore putting them at greater risk in the future.

“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:
i. 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;
ii. the temporary suspension will not jeopardize the survival of the species in Ontario;”

Suspending protections of species under the Act for three years would be tantamount to dismantling the Act altogether. This discretionary power of the Minister to suspend protections for “social or economic implications” leaves the door wide open for interpretation or manipulation of species protections when it becomes inconvenient for major development or industry. Species cannot be protected if we expect to be able to carry on as usual despite the presence of Species at Risk, and “deal with it later”.

The second point, in suspension of protections will not jeopardize the survival of the species is nonsensical. The Act, and the species protections included exist because without them, the survival of the species is in jeopardy. If suspending species protections would not jeopardize the species, they would not be listed as Species at Risk.

“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 vagueness of this “Conservation Trust” has the potential to allow many species to fall by the way-side while the discretion of the Trust can direct funds to projects with a greater public appeal, or economic benefit. Any cash-in-lieu program should require regulations and oversight to ensure that the funds paid are directed toward recovery of the species put in jeopardy by the activity. It is too tempting, and human nature to fund projects that will support species the public are familiar with or already have affection for.

All Species at Risk require protection to maintain the diverse balance of our ecosystem. The changes proposed in this Bill leave the door open to focus on a few favourite species, and suspend protections or de-list species causing inconvenience. The biodiversity of our ecosystem supports the balance of the planet. The species can be likened to the rivets holding an airplane together. If one rivet pops out, that airplane is almost certainly still safe to fly. But keep popping more and more rivets, and where is the point at which you are not going to get on that plane? Given the recent release of information by the UN on the global state of Species at Risk, it would be embarrassing for Ontario to take such a huge step backwards with regards to protection of the species that have the misfortune to live within our political boundaries.

Please reconsider. Without our healthy ecosystem, there is no economy, there is no society. We need to protect from the ground up, for the future.