I am providing my comments…

I am providing my comments on Bill 108 as a professional ecologist, hunter, fisher, and outdoor enthusiast.

I am extremely troubled by the proposed changes to Ontario's species at risk legislation. As a province that has already seen the majority of its southern landscape converted to to a combination of sprawling cities and suburban areas, intensive agricultural operations, and industrial sites, there is ample opportunity to develop and concentrate our economic activity in these already disturbed areas. It is certainly not the time to further expand our environmental impacts to the last remaining natural habitats in our province. The proposed changes to our species at risk legislation will foster exactly that.

Endangered and threatened species are our metaphorical canaries in the coal mine; they alert us to changes in our environment that not only threaten the endangered species, but also the human population and countless other species. Without adequate protections for our at-risk species, we will inevitably see further destruction of environmental features that provide ecological goods and services; in other words, there will be real financial costs to Ontarians, and these costs will be substantial.

Consider that many at-risk species rely on intact wetland and riparian habitats - the same habitats that are responsible for mitigating the flood risk of major precipitation and snow-melt events. The forests and wetlands these species often depend on are critical for storing precipitation that provides Ontarians with sources of clean drinking water. The alternative to protecting these habitats include: expensive infrastructure repairs due to flooding; large insurance losses; expensive water treatment facilities; pollution of our recreational waters that attract scores of tourists and revenue to Ontario, loss of recreational space for Ontario's anglers and hunters, and so on.

Bill 108 is sold as a means of improving the status quo, but it is clear this is not the case. Independent scientific designation of species as being at-risk or not, and prompt protection of these species following listing is critical to protect Ontario's wildlife and also our human interests as outlined above. We do not need industrial and developer interests providing their opinion on species designation - it is outside their field of expertise, and the feedback one can expect from these groups will clearly not align with the broader interests of Ontarians. Furthermore, even when a species is recommended for listing, you propose giving the Minister discretion on whether to list the species and whether to protect the species. We need a firm commitment to science-driven decision making, not a regressive turn to political decisions vulnerable to exploitation by special industrial and corporate interest groups that do not reflect the interests of the broader society.

I have reviewed the proposed changes, and frankly speaking, the entire proposal needs to be scrapped.

The cynic that I am, I don't expect much to come from my individual comments here. However, I can tell you that Ontario's outdoors enthusiasts, hunters, and anglers are upset about this proposed changes and others already implemented by the current government (e.g., discontinuation of Ontario's tree program). You can expect these important stakeholders to take the harmful policy decisions into account at their next opportunity to vote.