The proposed changes to the…

The proposed changes to the endangered species act are broad in scope and significantly damage the protections that this act provides to vulnerable species in our province. As outlined in the proposed changes my response to each section is as follows:

1. While I agree that providing earlier notice on a species assessment would be preferable, extending the time to listing said species from 3 to 12 months only considers the impact that a new listing has to developers. Allowing developers to complete work that could significantly damage the habitat of a newly listed species is short-sighted, and potentially damaging to the species. During a time when we are losing species daily at an alarming rate, this is the worst time to reduce protections and allow developers to potentially destroy habitat. B. Backdating this to 2019 is also not acceptable.

The minister, who has zero experience in ecology, biology, or the environment, should not have any say in the classification of a species or the re-assessment of any species. This is outside their purview and the reason COSSARO exists is to ensure an unbiased and science-based approach to listing species, allowing the minister to reconsider classification makes this decision entirely political in nature and is a step backward in the process.

This is a non-starter, species at the edge of their range are often adapted to the extremes of a species’ tolerance, by assuming that a species is secure in the center of its range and therefore secure in Ontario, we are removing protection for individuals that are specially adapted and may provide genetic advantages to the species as a whole. Further, the species may not be protected in the other country, which means the population in Ontario is providing a modicum of protection to the entirety of a species.

COSSARO should continue to only include professionals with relevant expertise, community knowledge is important, however, it is not always based in scientific fact, this could potentially harm a species as a whole, through the inclusion of knowledge that is incorrect or improper identification skills that grossly exaggerate a species range and population.

2. The listing process should continue to be automatic, each species that is provided with a status of concern is based on hard science and population trends, if the status is provided, and this species requires protection, they should be automatically protected, end of story. Without automatic protection and instead of an announcement of coming protection, this could cause rampant removal of habitat in order to avoid permits or hold-ups to development in the future, potentially causing even more damage to a species. Habitat regulation must continue to be required, each species is tied to its habitat and a habitat requirement, without this, the species is not truly protected.

3. Timeline extensions are required to ensure a species is adequately protected within reasonable timelines, while in some circumstances, extensions should be granted (where further research is required) in general, removing timelines is akin to removing protection. B. Recovery strategies should constitute policy, not advice to government. These strategies need to be implemented if we have any hope of maintaining a species into the future. C. allowances should only be provided in extreme circumstances and should continue to have a timeline/limit.

4. Paying a charge in lieu of protection is completely unacceptable, this model is not working in the United States, and the recreation of habitat in other areas is a complicated process that may not even produce positive results. We have barely scraped the surface on the specific habitat requirements of many species, and destroying habitat that clearly meets their needs and trying to recreate it elsewhere is not the solution. We should be expanding and protecting the habitat in situ, where the species occurs.

While I agree that there needs to be further oversight on the governments’ part during the permit process, as well as ensuring mitigation measures that are proposed are completed and followed. This is not the way and will lead to extensive damage to the habitats of vulnerable species. All developers can provide reasonable alternatives and reasonable excuses for why those alternatives could not be pursued from an economic standpoint. Economics should be much lower on the list of reasons not to protect habitat. A. an independent expert must be consulted, otherwise political and economic considerations will always be at the forefront of decision making. All individuals of a species, make up the species as a whole, each individual contributes to the species, especially in the scenario of species at risk, many species that are at risk are long-lived, and slow to mature, every individual matter.

ALL activity in the habitat of a species at risk newly listed or not deserves immediate protection, this change would once again only benefit the developer, and immediate protection is integral to keeping the species from continuing to decline.