Comment
The world is in an extinction crisis, with biodiversity disappearing at a rate not seen since the catastrophic impacts of a meteorite changed the earth almost instantaneously and caused the last mass extinction event. This time it’s different: equally catastrophic but rather than instantaneous, this is more like a train wreck in slow motion. And in Ontario, these proposed changes do nothing to slow the train; they simply accelerate it.
The UN says that 25% of plants and animals are at risk of extinction. This isn’t an epidemic happening just in far-away Africa or Antarctica- it is happening here, in Ontario, in our own backyards. Ontario is Canada’s most biodiverse province, largely because it is Canada’s deep south. We have much, but as a result, we also have more to lose than any other province.
Ontario has had an Endangered Species Act that offers protection to species in decline, and despite this, populations of a huge proportion of our province’s plants and wildlife are in decline. Bird populations have declined up to 70% in recent decades, largely due to habitat loss both here and in locations where they migrate and overwinter. Most recently aerial insectivore populations have plummeted, following the declines in the insects they eat (which is expected to be caused by neonicotinoid pesticides running off into local waterways- chemicals that kill insect life in minute parts per billion concentrations (but these are insects that perform huge ecological services- what do we lose when we lose them?).
I live in Hamilton, a municipality blessed with incredibly diverse habitats and therefore high biodiversity. However, we are also a municipality that is home to close to 60 species at risk, and that number is increasing every year or two, not decreasing. This isn’t because the ESA has been ineffective, though it could be ramped up. However, the proposed changes to the Act will undermine the current levels of protection and action that the Act now offers. The SAR number is increasing because new species decline to crisis levels each year due to habitat loss and environmental toxicity; the proposed changes to the Act will accelerate the rate at which many species will decline.
As it as been, the ESA is a piece of legislation that is meant to prevent decline and extinction; it should be to protect species, not to expedite development, and undermine the role that good science plays in our understanding of the environment and the interrelationship between species in the natural world. As is, the proposed legislation introduces an enhanced a risk of additional habitat loss and population declines. Further declines in some species may cause them to become extirpated from Ontario, and such losses to our natural heritage are unacceptable in the face of so many threats to biodiversity. We still have much to learn about how ecosystems work; for example, the role of flying squirrels as keystone species in deciduous forest ecosystems because they help to move and revitalize the soil fungi upon which so many species of Ontario trees and wildflowers (including Ontario’s own tree and flower emblems) rely upon. The decline and loss of this species of mammal would have a rapid catastrophic impact on our hardwood forests, already under siege from invasive species like garlic mustard and emerald ash borer, beech blight aphid, and perhaps soon, hemlock woolly adelgid. And climate change models, some of which include scenarios showing sugar maple as disappearing from much of southern Ontario over the next 30 years, as the tree’s climate envelope moves north. Aldo Leopold said, “the first rule of intelligent tinkering is to save all the parts.” These proposed amendments, and in particular Schedule 5 in its entirety, undermines this basic principle.
In particular, the public should be notified quickly of COSSARO’s species’ assessments, but listing should be immediate. Waiting one year after the species is listed could result in harmful effects on the species, especially with our changing climate creating additional pressure. Immediate protection is strongly recommended and there should be no possible suspension of listings for up to three years. As well, threatened and endangered species should have habitat regulations, as these species are especially vulnerable.
COSSARO is an independent committee with expertise in scientific disciplines and Aboriginal Traditional Knowledge and these individuals take great care and consideration when making decisions about which species should be listed as at risk, and this should remain the case. The Minister should not be able to overrule decisions made by COSSARO, as such veto power explicitly undermines the arms-length scientific approach that is supposed to be used to assess species and makes the process political rather than science-based.
COSSARO should not be expected to base its assessments on the status of a species throughout its range, as opposed to in Ontario only. For species that have a small portion of their range in Ontario, these populations often present unique adaptations and reservoirs of genetic variation, and this is critical today as these are the genetic tweeks that are likely to facilitate resilience to climate change. Loss of Ontario populations means loss of global genetic diversity in the species. Allowing species to be wiped out in Ontario simply because they occur elsewhere is short-sighted.
The proposed changes include amending the act to strike out “the environmental registry established under the Environmental Bill of Rights, 1993” and substituting “a website maintained by the Government of Ontario”. Such a change would mean that the opportunity for public input is lost. Removing opportunities for public input eliminates government accountability to the public and prevents the public to participate in the protection and recovery of species at risk.
It is true that better enforcement is necessary to protect SAR. There is a strong need for enforcement of the ESA through fines and if necessary, incarceration.
The purposes of the ESA as currently stated are in no way held up by the proposed changes.
The proposed changes do not align with the stated and intended purposes of the ESA. These changes will make it easier for industry and developers to destroy the habitats of our most vulnerable plants and animals, making disastrous permanent changes that destroy the legacy we hold for our children and grandchildren. Schedule 5 should be removed entirely.
Submitted May 18, 2019 11:57 PM
Comment on
10th Year Review of Ontario’s Endangered Species Act: Proposed changes
ERO number
013-5033
Comment ID
30845
Commenting on behalf of
Comment status