The Hamilton Naturalists'…

The Hamilton Naturalists' Club, representing 600 members and dedicated volunteers, welcomes this opportunity to comment on the proposed amendments to the Endangered Species Act.
We are celebrating our 100th anniversary this year as a human voice for the protection of wildlife and natural areas. We have always attached considerable importance to the preservation of endangered species in Ontario.
As such, we are deeply concerned about the major changes to the ESA unveiled in the government's omnibus housing bill, the "More Homes, More Choice Act," Bill 108. We believe changes to the ESA should have been completely separate from an omnibus bill, especially when the proposals threaten to weaken the ESA in many ways.
The fact that many leading conservation and environmental organizations believe the changes will be detrimental to endangered species should prompt the government to reconsider the changes and preferably remove Schedule 5 completely from Bill 108.
The HNC strongly agrees with the detailed criticisms of the proposed changes that have been outlined by Ontario Nature, in particular, as well as the Toronto Field Naturalists in their 7 May letter to Environment Minister, and many others.
For example, we believe the Environment Minister should not have broad discretion to interfere with the science-based listing of species, to suspend and limit protections, and to ignore legislated timelines for policies and reporting. Proposals for more ministerial discretion could result in harmful delays in recovery planning and ESA protections.
The HNC is also opposed to the proposed creation of a Species at Risk Conservation Trust, where developers and industries could pay into a fund in lieu of fulfilling requirements for on-the-ground reparation of the damage they inflict on species and their habitats. We agree with many critics who view a fee-in-lieu fund as an easy way out for proponents of harmful activities that reduces transparency and accountability. It is inconsistent with the purpose of the ESA, which is to protect and recover species at risk.
We also take exception to a proposal to assess species on the full extent of their range, rather than the status of a species in Ontario. The proposed approach could well mean that species near the edge of their range in the province would lose their protection in law. We find that unacceptable, especially in the face of climate change because healthy species populations are needed at their northern limits to help species adapt to changing climatic conditions.
The HNC believes the proposed changes are inappropriate, ill-considered and untimely. It is essential that Ontario show leadership in protecting endangered and vulnerable species such as the Algonquin Wolf, Boreal Caribou, Barn Owl, most of our turtles, and more. The urgency of strong action was underlined by the recent United Nations report warning that more than one million species are facing extinction over the next decade.
It is imperative for the government to recognize that endangered and vulnerable species must be protected with an effective legal framework. Ontarians should have confidence that the ESA will not be subject to "death by a thousand cuts," which is the direction that unfortunately the proposed changes would lead to.
We fully share Ontario Nature's conclusion that the proposals amount to sacrificing the recovery of species at risk to the advantage of those with vested short-term economic interests in unbridled development.
The HNC stands united with conservation organizations across Ontario in urging the government to remove Schedule 5 completely from Bill 108.
Thank you.