Thank you for the…

Thank you for the opportunity to comment on the proposed changes to the Endangered Species Act.
I am deeply concerned by the proposed changes to the Act and its procedures. Contrary to the claims made in the documentation, the changes will not improve outcomes for species-at-risk (SAR) as they will speed and empower those who propose damaging actions for individual species and their habitats.
These proposals come in the same month as a UN IPBES report that demonstrates a fifth of all life forms on Earth are at risk! Every jurisdiction has responsibility to protect species better.
Thus, the increased ministerial discretion to interfere with the scientific aspects of designation of species and habitats is deeply troubling and will surely lead to arbitrary abuses of power.
The “pay-to-slay” provisions are totally unacceptable and will lead to much damage to SAR and their habitats.
In summary, Schedule 5 should be removed from Bill 108. Additionally, future proposals of this kind should not be buried in unrelated legislation (A housing bill in this case). That smacks of secrecy and an intention to hide changes from the public.
My specific concerns follow (numbers and letters reference sections in the ERO listing):
1.A. Extending ministerial review to 12 months will impede urgent designation of endangered species
1.B. Making regulations retroactive is fundamentally abhorrent.
1.D. Allowing the Minister to require COSSARO to reconsider a decision made on a best-science-available basis, using other science (whose????) will interfere with COSSARO impartiality.
1.E. Excluding species based on their presence outside Ontario weakens the protection for those species. If every jurisdiction took this approach there would be no protection at all for many SAR.
1.F. COSSARO should remain a scientific committee. Adding other members muddies the waters by taking the political level of decision-making into the scientific forum.
2. Decoupling ministerial decisions from scientific information is unwise and damaging.
2.A. Suspension of protections for up to 3 years is arbitrary and potentially extremely damaging to SAR.
The “other criteria” wording allows the minister to essentially avoid the requirement of the Act, which will be extremely damaging to SAR and their habitats.
2A.i.4 This provision weakens the Act entirely and is thus potentially very damaging for SAR. Removing mandatory timelines is a recipe for inaction on urgent files. Removing cabinet responsibility is retrograde, indicating that the government has no regard for SAR.
3A. Timelines are removed: A recipe for inaction. What does ”for some species” mean? Does it indicate that some species are more important than others, in which case, what are the criteria?
3.D. Removing responsibility to post on the ERO is retrograde. It opens the door to political secrecy and is potentially undemocratic.
4. The “pay to slay” scheme is totally unacceptable. It surely must be reconsidered! And who would decide which species are on the chopping block? What are the criteria, if any?
Under “Additional Changes”:
A. This provision should not allow the minister to ignore expert opinion.
B. When a species is at risk, the problem does come down to individuals. It did with passenger pigeons and greater prairie chickens and eastern box turtles, and it will with every other species at risk!
C. Allowing ‘business as usual” for 12 months is open to extreme abuse of SAR.
F. This provision gives the Minister carte blanche. It is potentially very damaging for SAR as it appears to allow any other legislation to override the ESA.
G. This permits complete freedom to abuse any SAR!
5.B. This provision could allow non-expert personnel being deployed in situations that require expert judgment. Ministerial discretion is potentially open to abuse here.
The pause of protections is open to abuse and potentially very damaging to SAR.