Re: Bill 108, Schedule 5 …

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

Thank you for the opportunity to comment on the proposed changes to the ESA. I strongly oppose 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. Nor do I support the “pay-to-slay” scheme that would grease the wheels of destruction by allowing 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.

Improving outcomes for species at risk requires enforcement, not weakening, of the law. It also requires investment in stewardship, not writing off species at risk and their habitats as red tape.