I do not support the…

I do not support the proposed changes contained within the 10th Year Review of Ontario's Endangered Species Act, and I believe that the Ontario government has a duty to preserve the biodiversity and natural spaces we have left in Ontario for current and future generations. I have a Master's of Science specializing in wildlife biology and I currently work as a researcher who focuses on Molecular Ecology. I primarily work to create molecular tools that allow us to improve our ability to detect and monitor at-risk, endangered, and invasive alien species in our province. I believe this provides me with excellent qualifications to provide informed comments on the problematic changes proposed for this act.

Overall, I believe the proposed changes serve only to weaken the protections provided to endangered and at-risk species currently available in the province. We are currently experiencing a 6th mass extinction event on the planet and recent reports such as the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) provide key drivers of global biodiversity loss, such as “changes in land and sea use; direct exploitation of animals and plants; climate change; pollution; and invasive alien species”. All of these drivers of biodiversity loss are directly caused by human activities, meaning that it is our responsibility to change our behaviours in ways which minimize our harm on the environment.

Ontario was the first province in Canada to establish an Endangered Species Act and I believe that it is still our responsibility to raise the bar for environmental protections in our country, and across the globe. I believe that many of the proposed changes to the Ontario Endangered Species Act serve only to lower the bar we’ve set for protecting the environment and preserving our biodiversity. We are currently at a period of time where the rapid loss of biodiversity demands we increase our efforts to protect what remains, and I believe the proposed changes to the act inhibit our ability to do this.

Below, I outline what I believe to be the most problematic changes proposed:

1) Assessing species at risk and listing them on the Species at Risk in Ontario List
Currently, once COSSARO submits a report to the Minister, the species must be added to the SARO list within three months. The proposed changes suggest extending this time period from three to twelve months. This undermines the purpose of the Ontario Endangered Species Act and directly contradicts its purpose of providing timely protections to at-risk and endangered species so we can make efforts to protect and restore their habitats and populations. Additionally, the proposed changes suggest providing the Minister the power to veto recommendations put forth by COSSARO and this undermines the purpose of a committee of experts coming together to make recommendations that are informed by science and benefit the people of Ontario the most. The current Minister, Rob Phillips, also does not have a scientific background or any training in conservation or environmental policy and allowing him (and future Ministers who lack a scientific background) to have executive control over which recommendations pass is not in the best interest of the people of Ontario. Placing so much power in the hands of one individual’s position regardless of political affiliation also increases the risk of corruptive forces dismantling the Endangered Species Act which is explicitly not in the interest of this act.

2) Defining and implementing species and habitat protections
These proposed changes additionally reduce the automatic protections that would be granted by SARO and go against the interests of the ESA. As outlined above, putting this decision making process in the hands of the Minister whom is not required to have any background in conservation, population ecology, or biodiversity sciences opens up the Endangered Species Act to being easily corrupted against the interests of the species being protected by this act.

3) Developing species at risk recovery policies
Like above, this subsection of suggested changes will result in increasing delays which both do not need to happen and will have detrimental consequences on the species we need to be protecting. The current state of the global environmental crisis warrants an increased rapidity in response and action, not increasingly slowed decision making.

4) Issuing Endangered Species Act permits and agreements and developing regulatory exemptions
Issuing a system which allows for those with vested interests in land misuse an opportunity to pay a fee to openly destroy protected habitats and risk the long term success of at-risk and endangered species fundamentally goes against the changes we need to be making to protect local biodiversity. As outlined in the recent IPBES report, land misuse and direct exploitation of plants and animals are some of the leading causes for the rapid biodiversity loss we are seeing across the globe. A system in which you can pay to misuse protected lands and directly exploit the plants and animals which exist there will only further exacerbate the biodiversity loss being seen in Ontario. This is in direct contradiction to the purpose and goals of the Endangered Species Act and to allow these to go through is unconscionable. Lastly, providing the Minister with the power to work without expert consultation and based largely on their opinion of whats best for the species of concern is a massive oversight which opens too many opportunities for decisions to be made against the best interest of the species at hand, for the current Minister and for future Ministers.

In summary, I do not support the proposed changes to the Ontario Endangered Species Act. The changes propose “… to improve the effectiveness of the program for species at risk by ensuring Ontario’s best-in-class endangered and threatened species protections include advice and species’ classifications from an independent scientific committee and modern approaches to enforcement and compliance; species and habitat protections; and recovery planning.” However, as I’ve outlined, the recommended changes work directly against meeting these goals.

The proposal is ignoring the advice of an independent scientific committee of experts and creating justification to do so further. It is severely crippling enforcement and compliance. It is weakening species and habitat protections. It is delaying recovery planning. It is giving unnecessary and damaging authority to the Minister, who has no reason to veto, suspend or delay species at risk protections and increases the risk of extreme ecosystem harm should the current or future Minister become corrupted and begin making decisions which benefit those who want to misuse Ontario land and exploit native species. In no way do the proposed changes meet the goal of the ESA.