A2A Endangered Species Act…

A2A Endangered Species Act submission, May 2019

Re: ERO # 013-5033

The Algonquin to Adirondack Collaborative is an environmental charity which works to protect wildlife and to maintain habitat connectivity for wildlife through the broad region from Algonquin Park in Ontario to the Adirondack Park in New York State. We have over 50 partner organizations and 200 members which we collaborate with throughout the A2A corridor. We envision an Algonquin to Adirondacks region that is a resilient, with an ecologically connected landscape which sustains a full range of native wildlife. A critical component of this vision is protecting our most endangered species at risk based on objective scientific evidence and respect for wildlife.
As an organization which focusses on protecting habitats and species in this critical biological corridor, we have serious concerns with the proposed changes to the Endangered Species Act, 2007. In particular:

• The Act and its protective provisions under the proposed changes would become much more discretionary rather than science based. The ability of the Minister to second guess recommendations of the Committee on the Status of Species at Risk in Ontario (COSSARO), and delay listings based on social or economic considerations compromises the science-based approach.
• Numerous changes are aimed at delaying possible listing and implementation, time which can make the difference between effective protection of species and significant species and habitat loss. The 3 year delay for economic and social considerations, the one year extension for review of COSSARO recommendations, the one year delay for application of protective provisions for existing permit holders, provisions allowing for indefinite delay of Government Response Statements to Recover Strategies, and the Ministerial discretion proposed for carrying out a review of progress (rather than the current 5 year requirement) all point to loss of protection and a movement away for an objective, science-based approach to endangered species.
• Provisions that limit the geographic extent of assessments – in particular the requirement that COSSARO assessments be based not on the status of species in Ontario, but on status across a “biologically relevant range” – ignores the importance of transitional areas at the edge of ranges. A2A represent a significant and rich biological area in part because it is a transitional zone between northern and southern species. If an extended range is applied to the assessment of species, significant protection could be lost in the A2A area and a key factor in adjusting to climate change (the protection of species as they adjust to changes climate zones) will threatened.
• Recommended changes that make it easier to obtain permits for harmful activities also threaten the integrity and purpose of the Act. Such measures as providing a fee-in-lieu of protection option, removal of the requirement for the Minister to consult independent experts prior to issuing permits that are deemed to provide social or economic benefits, creation of landscape agreements for multiple harmful activities throughout an area, and removal of protections for individual members of a species, all limit the ability to ensure that permits do not result in the incremental loss species by providing a much broader scope, both geographic and political, for the issuing of harmful activity permits.

In conclusion, A2A has serious concerns with many of the proposed changes and can see significant negative impacts in the A2A which has many species at risk. As a significant biological corridor in a transitional area, with a relatively intact landscape, an effective, science-based approach to protecting endangered and threatened species as a key component to protecting the A2A corridor today and for future generations. We strongly urge the Ontario Government to reconsider these changes and undertake further work to ensure an effective and science-based approach to protection of our endangered and threatened species.

David Miller
Executive Director, A2A, on behalf of the A2A Board of Directors
613-220-7482