ERO 013-5033 I appreciate…

ERO 013-5033

I appreciate the opportunity to express my disappointment with the weakening of the Endangered Species Act proposed in Bill 108 Schedule 5. This Bill has been published co-incident with a UN Report by the IPBES which warns of

"an imminent rapid acceleration in the global rate of species extinction. The pace of loss is already tens to hundreds of times higher than it has been, on average, over the last 10 million years…Half-a-million to a million species are projected to be threatened with extinction, many within decades. Many experts think a so-called "mass extinction event -- only the sixth in the last half-billion years -- is already under way” (1)

Biodiversity and Land System Change, in addition to Climate Change, are among the nine planetary boundaries suggested by the Stockholm Resilience Centre that should not be transgressed and should be considered as a precondition for sustainable development. Bill 108 is a threat to biodiversity and will result in more forests, wetlands and other types of vegetation being converted to human use. It promotes development without sustaining Ontario’s natural heritage and is environmentally irresponsible.

Two of these, climate change and biosphere integrity, are what the scientists call "core boundaries". Significantly altering either of these "core boundaries" would "drive the Earth System into a new state”. “Transgressing a boundary increases the risk that human activities could inadvertently drive the Earth System into a much less hospitable state, damaging efforts to reduce poverty and leading to a deterioration of human wellbeing in many parts of the world, including wealthy countries," says Lead author, Professor Will Steffen, researcher at the Centre and the Australian National University (2)

I fear bill 108’s protential to remove or downgrade species (flora and fauna) from endangered status. In a recent example of the impact this bill will impart, the dune system is being prepared for destruction at Sauble Beach, leading to piping plover (that were just making a comeback) becoming extinct again in the Great Lakes. Just one of many species this bill risks stripping protection away from.

Wildlife biologists and conservation policy experts were most alarmed by a provision that requires the committee of scientists that recommends species-at-risk listings to the ministry to look beyond Ontario’s borders at how the species is faring elsewhere. If considering the condition of the species outside Ontario would result in a lower level of concern — for example, a “special concern” designation rather than “endangered” — the committee must use the lower classification. (3)

Section 6 and 8 of the bill establishes the Species at Risk Conservation Fund, otherwise called the “pay to slay” plan. To use the plover example, a developer can develop plover habitat and then pay towards a generic fund to protect some other random species rather than the one being impacted by the landscape agreement. How can any species be protected when there is always an option to pay to destroy habitat? Section 7 gives other options to developers to bypass prohibitions under sections 9 or 10 of the original act. Section 3 allows the MoE the ability to suspend section 9 and 10 prohibitions up to three years. In effect, Bill 108 has undermined the intention behind the Endangered Species Act, which was to preserve flora and fauna in Ontario for future generations, leaving some natural areas undeveloped.

I am alarmed at the loss of species to date in Ontario, Canada and the world. Insects, those creatures at the bottom of the food chain that include pollinators, beneficials and soil creators, have had huge declines (windshield phenomena). A 2017 WWF study notes an 83% decline in vertebrates in Canada since 1970, and specifically a 69% decline in grassland birds, 51% insectivores, 43% shoreline birds. COSEWIC states 44% of amphibians and 65% of reptiles are endangered or threatened. Not to mention that when we remove trees and plants from the environment, we reduce carbon being extracted from the air, contributing to global warning.

I disagree with Bill 108 schedule 5 for its providing the right of destruction of habitat with a potential to drive more Ontario species to extinction, ignoring the warning of scientists of the risks to humans from this destruction. Destruction of natural habitats causes biodiversity to fall to unsustainable levels. In response to the notion that Ontario doesn’t currently have enough space to build cheap housing, I observe that in Vancouver, recent taxes on foreign ownership drove down rental prices, providing reasonable options for affordable housing. (4) Our last remaining protected natural spaces, including farmland, should not be rezoned and should be protected from urban sprawl. We should develop areas already zoned residential without targeting the last remaining pristine spaces. And yes, I want piping plover rearing their young in the Great Lakes.

references:

(1) https://www.france24.com/en/20190423-one-million-species-risk-extinctio…
(2) https://www.stockholmresilience.org/research/research-news/2015-01-15
(3) https://www.thestar.com/news/gta/2019/05/04/sweeping-changes-buried-in-…
(4) https://www.dailymail.co.uk/news/article-6932243/Vancouver-college-kids…