I am distressed that Bill…

I am distressed that Bill 108 has already been released prior to consideration of public comments on the ERO. Despite the claims of the Ontario government to improve protection of endangered species, the proposed changes will weaken protection of species biodiversity:

• Proposal to reassess species based on broader geographic range outside of Ontario will potentially drastically reduce the number of species classified as endangered or threatened thereby removing protection for these species.
• Proposal to make species protections optional rather than mandatory based on minister’s discretion will take the decision from being science-based to being based on political considerations.
• Proposal to remove the requirement for the minister to seek advice from an independent expert on whether survival of a species would be jeopardized prior to creating a new regulation under the ESA or when issuing a permit to harm a species for economic benefit.
• Proposal for extended delays for protection of newly listed species, issuing recovery strategies, and issuing of Government Response Statements for plans to implement species protections.
• Proposal to remove the requirement for projects to provide an overall benefit to negatively impacted species with only needing steps to minimize adverse affects.

The ESA needs to be strengthened by removing the existing broad range of exemptions for industry activities rather than weakened through the proposed changes.