The proposed changes to the…

The proposed changes to the Endangered Species Act 2007 have been broadly outlined into five categories in the ERO propopsal. I have specific issues with some of the proposed changes, and have itemized them according to the five categories.

1.Assessing species at risk and listing them on the Species at Risk in Ontario List
-The proposed changes to the listing of species on the SARO List (namely, earlier notification to the public with increased lag between notification and addition to the list) will not strengthen the protection of species at risk and should not be enacted. The functional application of this proposal warns people who might need to remove potentially protected habitat/species earlier and gives more time to enact that need.
-The proposed changes around considering a species' broader geographical condition is more likely to weaken a species' protection in Ontario, and should not be enacted. The reason Ontario has an Endangered Species Act is to protect Ontario's species at risk, and this is not achieved by considering a species conservation concern in other regions, such as other provinces, nationally or internationally.

2.Defining and implementing species and habitat protections
-The proposed changes regarding de-coupling the listing process from automatic protection for up to three years does not strengthen the protection of species at risk in Ontario. If a species is listed, but its habitat/species protection is not in force for a three year review period, there is no meaning to the species being listed. COSSARO has already justified why it needs protection by having it listed, and delaying the force of the protection under any circumstance to determine a species-appropriate habitat/species protections is redundant.

3.Developing species at risk recovery policies
-The proposal that recovery strategies are advice and the Government Response Statements will be policy is not likely to strengthen protection of species at risk. This proposal allows the government to ignore the scientifically based recommendations for any reason.
-The proposed changes to allow for extended timlines for review of progress towards protection and recovery will not increase the protection of species at risk in Ontario. The greater lag between submission of and response to recovery strategies, in tandem with the other proposed changes to the ESA 2007 regarding timing of protections, allows more time for the destruction of species at risk and their habitats.

4.Issuing Endangered Species Act permits and agreements, and developing regulatory exemptions
-The proposed creation of a Regulatory Charge and Agency will not strengthen the protection of species at risk in Ontario. This entire approach simplifies a very complex issue that affects all residents of Ontario. There is nothing redeemable about this proposal. Paying fines is not acceptable - no one bred or built the species at risk or their habitats, and so paying to destroy them is not equal restitution. Further, these natural features cannot be recreated and are invaluable because of that.

In summary, as an Ontarian - a resident, father, taxpayer, and business owner -I am generally not in favour of the intent of any of the proposed changes to the Endangered Species Act 2007. None of the proposed changes stregthens protection of species at risk in Ontario. These changes instead weaken the Act such that most species at risk and their habitats could be destroyed before my children have time to enjoy and benefit from them. Our human existence is more dependent on the diversity around us than this government knows, and the proposed changes reflect that ignorance. These changes are not for the people, they are not even for the birds! These changes to the ESA must not be enacted.