I have a background in…

I have a background in biology and ecology and have taught at an Ontario university for 25 years. I am very familiar with population ecology, the function of organisms within their communities, and the nature of rarity and strategies for conservation. I have also been a central participant in a number of important scheduled reviews, such as a Regional government 20-year Official Plan review, 10-year academic department reviews (3 occasions), and the 25 year review of the largest cooperative education program of any Canadian university (this took one year and about 200 hours of my time). I have also sat on a Regional government arms-length ecological and environmental advisory committee that was heavily involved in assessing and advising habitat and species protections when development proposals affected legally designated high-quality natural areas.Thus I am very familiar with how effective review processes should be conducted, as well as the specific content of endangered species investigations.

This review process is a great disappointment. It looks like political and developer interests are well entrenched and take precedence over the central concern of conservation of species. I notice how often the pat phrases of such interests are used: "modernize", "streamline processes", "reduce duplication". The "review" is happening far too quickly and there does not appear to be any opportunity to engage in official hearings or interactive consultations. It is stated that consultations have occurred, but not with whom. That should be transparent. It does not appear to include scientists, conservation organizations, environmental groups, and experts.

1D This much Ministerial discretion is dangerous. ("Allow the Minister to require COSSARO to reconsider the classification of a species where the Minister FORMS THE OPINION based on scientific information that the classification may no longer be appropriate".) As far as I know the present Cabinet has no biologist on it. Also, such important changes require more than just an "opinion".

1E The requirement to consider a species' condition around its broader geographic area outside Ontario is concerning. We are entering a period of profound climate uncertainty and environmental warming. The genetic makeup of organisms at the outer limits of their distribution may represent a suite of adaptive abilities that will be crucial to contend with such changes.

1F The makeup of the CASSRO committee, as well as the selection process, are important. What are the present criteria for membership on the committee? What constitutes "community knowledge"? I feel it is paramount that the committee include a climate scientist.

2A "Decouple the listing process from automatic protections and provide greater Minister's discretion on protections, while keeping the assessment as a science-based process at arm's length". There are several contradictions here. The minister would be allowed to ignore whatever they want.

2A "provide the Minister with authority to temporarily suspend species and habitat protections for up to three years", if "the species would likely have significant social or economic implications for all or parts of Ontario'. Certainly good studies should be made, but a 3 year suspension could also be a death sentence for an endangered species.

2C Remove requirements to develop a habitat regulation proposal for newly-listed species. Please consider that such habitat regulations will be used to guide decisions not just at the provincial agency level, but - and probably even more often - at the municipal level.

3D Remove specific reference to posting under the Environmental Bill of Rights.. NO! That is a very bad move. Simply putting documents on a government website is too dodgy and subject to political abuse. In Canada we have had the unfortunate experience of the Federal government removing scientific reports from websites, muzzling civil servants and scientists, and obliterating references to climate change, which it found particularly distasteful to its political beliefs.

4 The regulatory charge. This is a shocking and shameful proposal. I've seen the phrase "pay to slay" used to describe it. Unfortunately, it's a vey accurate descriptor. In my 10 years work with a Regional Ecological and Environmental advisory committee I noticed a consistent positive change in the quality of environmental assessments produced by developers and particularly their ability to design more sophisticated and effective rehabilitation plans. We should be interested in encouraging such leading-edge corporate capabilities. Allowing them to simply pay their way out of a conservation problem rather than developing enhanced expertise in problem solving (and by implication developing a competitive corporate advantage) is disturbing and regressive.