I am concerned about the…

I am writing to express my concerns about the changes to Ontario’s Endangered Species Act. Ontario is 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.

1. I am deeply concerned about the proposed change that would allow developers and municipalities to pay a fee in lieu of undertaking on-the-ground protections for SAR. You state that the funds collected would be used "to fund only those activities that are reasonably likely to support the protection and recovery of prescribed species."First, the term "reasonably likely" is weak and open to too much interpretation that could cause further damage to SAR. Second, I disagree with this tactic and would argue that the best activities that are "reasonably likely" to support the protection and recovery of prescribed species at risk are to not allow further development where they currently exist and to not offer a way to pay. Allowing developers to pay a charge rather than dealing with the impacts on SAR directly will disconnect the developer from understanding the impacts of their actions on the local environment. Furthermore, it is stated that the developers would still need to consider "reasonable alternatives" for their activities, and would have to take "steps to minimize the adverse effects of the activity on SAR," but I think this language is also weak and open to too much interpretation that could effectively cause more damage to species at risk.

2. I disagree with the proposed change that would "Require COSSARO to consider a species’ condition around its broader biologically relevant geographic area, inside and outside Ontario, before classifying a species as endangered or threatened." Many species at risk in southern Ontario are at the northern limits of their ranges which can extend into the United States. The northern populations of SAR in Ontario, and habitat for species at risk in Ontario are important for future adaptation to climate change for the species at risk in all of its range.

3. I disagree with the proposed change to the ESA that would "De-couple the listing process from automatic protections" and grant the minister more discretion to suspend protections for species for up to three years if the prohibitions would have social or economic impacts. Placing concern for economy over the environment is one of the main reasons why there are species at risk of extinction in the first place, so putting the ability of the Minister to suspend protections for economic concerns is counter intuitive and will undermine species protections in Ontario. Automatic protection is the best way to protect species at risk.

4. I am concerned about broadening the membership of COSSARO to those who have "community knowledge." This is a vague term that needs to be further defined because it is too open to interpretation and could open up COSSARO to people that have a different agenda or don't have adequate conservation knowledge to make informed decisions. COSSARO needs to be upheld as an expert panel of scientists that understand how to scientifically assess species at risk.

5. I disagree with the proposed change that would remove the requirement of the Minister to consult with an independent expert in the regulatory and permitting process. Experts are experts for a reason, and there should be independent experts to keep the Minister in check.

6. I am concerned about the proposed changes that would allow the Minister to delay the nine-month Government Response Statement and to "extend timelines for conducting the review of progress towards protection and recovery based on individual species’ needs." Furthermore, I am strongly against the proposed change to delay the time period for when the Minister has to list a species based on COSSARO's report from 3 to 12 months. That is an extra nine months of delay where species at risk are not protected from killing, harm, or habitat destruction. The UN just released a major report stating that over 1 million species are at risk of imminent extinction. We need swift action to protect Ontario's biodiversity, not more delays.

7. I am opposed to the changes in the listing process that would "Allow the Minister to require COSSARO to reconsider the classification of a species" that is not currently listed based on the opinion of the Minister. Allowing the Minister to send back, for a second review, a recommendation from COSSARO to list a species is another delay that will allow continued killing, harm, and habitat loss of species that need protection. There is no timeline stated for this process which could effectively mean that the fate of the species protection could be in limbo for months to years. Furthermore, the power that would allow the Minister to suspend a species listing should be removed from the proposed changes as this power would result in threats to the species at risk to continue. These proposed changes will result in fewer species being listed and for the status quo of species loss and extinction to continue.

The proposed changes are inconsistent with, and will undermine the purpose of, the Endangered Species Act which is to protect species at risk in Ontario. I mentioned this already but the UN just released a report outlining the fact that over a million species are at risk of extinction worldwide and that the extinction rate is accelerating. The primary driver of loss is changes in land and sea use. The proposed changes to Ontario's ESA would allow for more land to be altered by development without consideration of species at risk. I would also like to mention that another report was just released that states that Canada is warming at twice the global rate which will place added stress on species at risk, so more protections need to be in place, not more delays.

By rolling back protections on species at risk in Ontario through these proposed changes, the government of Ontario is not showing any actual concern for the future of Ontario's biodiversity and is continuing with the status quo of favouring economy over environment. These two things, economy and environment, are not mutually exclusive. We need a healthy and thriving ecology to support a sustainable economy, and we are at a point in history where we need to be creative and build the economy in ways that don't undermine the integrity of the environment by focussing on green energy and ecological restoration.

Thank you for accepting my comments on this issue.