I am concerned about the…

I am concerned about the changes to Ontario’s Endangered Species Act. We are the most densely populated province with the highest concentration of endangered species. If there is any province that needs evidence-based decision making it would be Ontario. Development and conservation are not mutually exclusive. We just need to be smarter about how and where we develop and how we plan to restore or mitigate this impact. I am concerned about the short sightedness of some of the changes being made to the Act.

1) I am concerned about the development of a land trust instead of the requirement to do protection activities. Recovery and conservation need to be priorities, and this should focus on the habitat that was disturbed. Many of these species having a fidelity to their habitat, and so offsetting habitat elsewhere will not produce an equivalent benefit. I am also concerned about the loose language that funds are “reasonably likely to support the protection and recovery of these species”. This allows for too vague of an interpretation of what actions need to be taken.

2) I am concerned about abandoning the “edge of range” species. With climate change the genetic diversity of these northern populations will become more important with the northern migration of species.

3) I am concerned about changes that limit protections, veto protections, bypass ESA requirements and bypass consultations. Critical habitat ought to be critical habitat regardless of who or what is being proposed.

4) I am concerned about the delays in the listing and changing of status of SAR that is proposed to occur. We ought to be adapting to the problem on a time scale that is representative of the problem and not delay listings by up to 5 years. Assessing species that may be at risk takes time while often that species status continues to decline. By the time COSSARO presents a status report to the minister recommending listing that species is AT RISK and action needs to be taken immediately (or should've been taken much sooner). Suspending and postponing protections to that species will allow that species to continue to decline while it awaits the protections it deserves and desperately needs. Therefore, any temporary suspension to species and habitat protections for some newly-listed species when specified criteria are met, would automatically not be able to meet criteria ii "the temporary suspension will not jeopardize the survival of the species in Ontario". This criteria essentially prevents the suspensions from being possible but including it creates ambiguity and room for uninformed and reckless decisions by people who are insufficiently educated in the subject matter.