Hello, I'm writing to…

Hello,
I'm writing to express my concerns over proposed changes in 013-5033. We've seen unprecedented declines worldwide in species declines due to human activity world wide. We need to continue to act locally, as a province to protect species and biodiversity in Ontario. The proposed changes allow people to pay when developments threaten habit. It also ignores empirical evidence and lets those with no science background to decide. We need to understand how important it is to protect species at risk within Ontario and be leaders in their protection. It shouldn't be about the edge of their range in Ontario but show how Ontarian's value nature. We need to be a voice for wildlife not continue to abuse them by allowing habitat destruction.

I've researched various other input and concur that the changes proposed do the following:
1. ‘Pay to Slay’: Ministry of Environment, Conservation & Parks (MECP) wants to allow developers & other proponents of harmful activities to pay into a fund rather than fulfilling requirements for on-the-ground compensation. This reduces accountability, making it far easier to proceed with activities that harm species at risk & their habitats.

2. Rejecting Science: The Committee on the Status of Species at Risk in Ontario (COSSARO) is comprised of qualified scientists who perform science-based assessments of whether a species is at risk. MECP is proposing to broaden COSSARO membership so that it includes those with “community knowledge” – a vague term that could open up COSSARO to those who do not have adequate expertise in species assessment or have a different agenda altogether.

3. Deserting “Edge of Range” Species: COSSARO would be required to base its assessments not on the status of a species in Ontario, but instead on its status throughout its range. For example, southern Ontario endangered species at the northern limit of their range may receive less or no protection, depending on their status outside Ontario. This is especially concerning in the face of climate change because healthy species populations are needed at their northern limits to help species adapt to changing climatic conditions.

4. Limiting Protections: The Minister would be able to limit Endangered Species Act (ESA) protections so that they apply only in specific geographies or under specific circumstances. This could exclude important habitats and species from protection.

5. Ministerial Veto of Automatic Protections: The listing of species at risk would be “de-coupled” from automatic protections for threatened & endangered species & their habitats and the Minister would have greater “discretion on protections.” They could suspend species & habitat protections for up to three years based on social or economic considerations. Such delays would be exempted from Environmental Bill of Rights posting & consultation requirements, leaving the public with no notice & no input on such decisions. Meanwhile, those with political connections could undermine species protections without full public scrutiny.

6. Sweeping Authorizations for Harmful Activities: MECP proposes to create “landscape agreements” for proponents undertaking harmful activities in multiple locations. Such an approach does not lend itself to addressing site-specific or species-specific concerns and consequently presents unwarranted additional risk for species already in peril.

7. Dodging ESA Requirements: MECP wants to allow activities approved under other laws to be carried out without any additional authorizations under the ESA, even if they harm threatened or endangered species or their habitats. This could result in permanent exemptions from the ESA for industries like the forestry sector.

8. Interfering with the Listing of Species at Risk: The Minister would be able to require COSSARO to reconsider its science-based listing decisions. This change would make it possible for developers and others who have the ear of government to derail the listing process if they don’t like a COSSARO decision.

9. Goodbye Expert Input: Currently, the ESA requires the Minister to consult with an independent expert prior to creating regulations that would jeopardize the survival of a species, or issuing permits for harmful activities that would provide a significant social or economic benefit to Ontario. This requirement would be removed.

10. Delays, Delays, Delays: Multiple delays are proposed for the listing, planning and reporting on species at risk, undermining species recovery. The proposal to list species nine months after COSSARO makes its assessments public – during this time vulnerable plants, animals and their habitats could be eliminated before protections kick in.

Thank you for your consideration.