To Whom it May Concern, I am…

To Whom it May Concern,

I am deeply troubled by the recently proposed changes to the Endangered Species Act of Ontario. These changes seem to prioritize development over protecting species at risk, mainly by making it easier and more efficient for large companies to abide by the legislation, and therefore ultimately removing accountability for their actions. Below are a few of the main concerns I have:

1A: increasing time until species must be listed under the act from 3 to 12 months. If a species has been listed by COSSARO, that means it is in immediate need of conservation action. Extending the listing time effectively makes it easier for companies to fit in projects and continue to harm species for a full year, by which point significant damage could be done. I urge the government to put more emphasis on the listing process (i.e. to ensure species are properly being listed), rather than weaken the very fabric of the legislation.

1E: Require COSSARO to consider a species’ condition around its broader biologically relevant geographic area: the Endangered Species Act of Ontario is provincial legislation, with the mandate to protect species within the province. Therefore, it seems strange that a species' protections should be dependent on populations outside of Ontario. Furthermore, COSSARO already considers the status of feeder populations in its assessments, and therefore no changes are needed to this part of the legislation. Ontario is home to a variety of rare species at the northern edge of their ranges (e.g. Carolinian species), and the act currently has the power to protect these species. I think this proposed change demonstrates a lack of undrstanding for natural ecology as well as the purpose of conservation legislation.

4: the Species at Risk Conservation Trust: while no doubt well-intioned, this has disastrous potential. Arguably the largest challenge to natural conservation is not funding, it is a lack of resources. Large development and infrastructure companies must be held accountable for their actions, and they can do this by complying with the current mandate of the act to make efforts to avoid harm and create additional habitat for species at risk. This trust will make it very easy for companies to do what they please without actually having to help protect species at risk; it is simply impossible for one trust to cover all types of conservation problems at a provincial scale. I strongly advise the government to reconsider creating this trust - it will remove accountability from companies that are largely responsible for harming species at risk and seriously undermine the purpose of the legislation.

I believe that any reasonable inspection of these proposed changes would lead to the conclusion that the government is signifigantly weakening this legislation. Many of these changes are directed to undermine species' protections while making it easier for polluters and habitat-destroyers to further harm species at risk. I truly hope the government will see the potential harm that could be caused through by changes and reconsider their position.