Re: Bill 108, Schedule 5 …

Re: Bill 108, Schedule 5 (ERO 013-5033) Proposed Amendments to Ontario’s Endangered Species Act

I oppose many of the changes that are being considered. They will not improve outcomes for species at risk. On the contrary, they would make it easier for industry and developers to destroy the habitats of our most vulnerable plants and animals.

More specifically, I do not support changes which would introduce broad ministerial discretion to interfere with the science-based listing process, to suspend and limit protections, and to ignore legislated timelines for policies and reporting (eg. sections 8.1, 8.3, 8.4, 16.1). This includes opposition to the broadening of the potential membership of COSSARO beyond professional voices in the sciences of ecology and related areas. The proposed members with “knowledge of the community” could easily be chosen from groups with vested interests that run counter to the best interests of local species at risk.

In particular, and most especially, I strongly oppose the provisions, set out in sections 20.1-20.18, that allow developers and other proponents of harmful activities to pay into a fund in lieu of fulfilling requirements for on-the-ground reparation for the damage they do to species and their habitats. This is a de facto hunting licence for endangered species. No amount of money in any fund will reverse the legally permitted local extirpation or broader extinction of a species at risk.

Improving outcomes for species at risk requires reinforcement, not weakening, of the law. Species at risk have no voices to speak for themselves to government. Nor should developers, with vested interests that are very frequently in conflict with the existence of these species, be given a stronger voice in their fates. Protection of species at risk requires continued investment in science based stewardship rather than the writing off of species at risk and their habitats as impediments to “progress”.