Cc: Honourable Rod Phillips,…

Cc: Honourable Rod Phillips, Minister of the Environment, Conservation and Parks
Cc: Honourable Peggy Sattler, Member of Provincial Parliament, London-West
Cc: Environmental Registry of Ontario (ERO)

Re: Bill 108, Schedule 5 (ERO 013-5033) Proposed Amendments to Ontario’s Endangered Species Act

Thank you for the opportunity to comment on the proposed changes to the Endangered Species Act. I strongly oppose the changes that are being considered. They will not improve outcomes for species at risk. On the contrary, they would make it easier for industry and developers to destroy the habitats of our most vulnerable plants and animals. This will not benefit the citizens of Ontario.

More specifically, I do not support changes which would introduce broad ministerial discretion to interfere with the science-based listing process, to suspend and limit protections, and to ignore legislated timelines for policies and reporting. Nor do I support the proposed changes that would allow developers and other proponents of harmful activities to pay into a fund in lieu of fulfilling requirements for on-the-ground reparation for the damage they do to species and their habitats. Conservation banking would require extensive study and review to be successful, and the time lag associated with implementing projects of value would not keep pace with the destruction of species and their habitats. Basing the protection of species on a global population, not a provincial population, not only ignores the impacts that climate change will have on species movements, with southern species needing to move north to survive, it also relies on assuming other countries are providing an appropriate level of protection to species, which the United States is not.

Many of the concerns expressed about the Endangered Species Act are not with the legislation, but with implementation. Continuing cuts to the ministries that enact these laws only increases wait times. Improving outcomes for species at risk requires enforcement, not weakening, of the law. It also requires investment in stewardship, not writing off species at risk and their habitats as red tape. The habitat that these species rely on provide countless benefits to the citizens of Ontario, including clean air, clean water, flood mitigation, and other ecosystem services. Development at any cost is not what the people of Ontario have asked for.

Given that the changes to the Endangered Species Act have been included in Bill 108: More Homes More Choices Act, the following quote seems appropriate to consider.
"We consider species to be like a brick in the foundation of a building. You can probably lose one or two or a dozen bricks and still have a standing house. But by the time you've lost 20 per cent of species, you're going to destabilize the entire structure. That's the way ecosystems work."