Comment
At first glance the Species at Risk Conservation Fund appears to be a positive move, but first appearances can be deceiving.
Certainly, species at risk and even some extirpated species need all the help they can get to survive and thrive, in order to maintain both the health of the species and our province’s biodiversity.
On further study, this proposal is seriously flawed and dangerous to the very goals it claims to support. It is naïve, at best, to think that a rich natural habitat that has evolved for centuries in one location can simply be replaced by a new restoration effort somewhere else. Based on my own personal experience at visiting historically intact sites vs more recently “restored” or “re-naturalized” sites, there is a vast difference in the biodiversity that can be observed at both types of locations. To put it simply, it’s like Humpty Dumpty – all the king’s horses and all the king’s men can’t put a natural ecosystem together again! That doesn’t mean that restoration and re-naturalization and recovery programs aren’t worth doing – yes they are, but they are complicated undertakings, and it all works so much better if there is an intact high quality site and healthy population nearby from which organisms such as insects and reptiles can expand outward to take advantage of new habitat.
There are serious flaws in this proposal:
- First, the concept of paying into the fund to have a license to circumvent existing protections is fundamentally flawed: as explained above, no amount of compensation can take the place of the original centuries-old habitat and well-established populations.
- Second, there is no requirement to provide an overall benefit to the species, where unavoidable losses and harms to habitat would be more than compensated by overall improvements. In fact, there is no reference to the measurement and evaluation of long-term outcomes and accountability for recovery results. All the proponent has to do is pay something up front and then they are home free.
- Third, existing habitats that support key target species also support diverse but less charismatic species that may not even have been studied yet, such as tiny insects, obscure fungi, etc.; by protecting existing high quality habitats we are preserving a complex inter-dependent community that we are only beginning to understand.
- Fourth, the concept of “pooling resources” in the fund paves the way to more funds going to species that capture the public’s attention (as the monarch has done), while other species that are less well-known or more difficult to successfully restore get neglected.
- Fifth, there is no commitment by the government to provide the long-term financial support required to carry out successful recovery and reintroduction efforts.
Over the years I have seen well-intentioned restoration projects end up supporting a small number of species – the opportunists that can thrive almost anywhere. To the untrained eye the result may appear “natural” but the complex diversity that makes up the web of life is absent.
I strongly urge the government to go back to the drawing board and develop an endangered species fund that puts the preservation of Ontario’s natural heritage first (not the desires of developers).
Submitted December 16, 2020 4:13 PM
Comment on
A proposal under the Endangered Species Act to enable use of the Species at Risk Conservation Fund and to streamline authorizations for certain activities that impact species at risk, while maintaining protections for species at risk
ERO number
019-2636
Comment ID
50341
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Comment status