Comment on ERO 019-2636…

Comment on ERO 019-2636 Species at Risk Conservation Fund:

I am disappointed that the Ontario Government would seek to introduce the Species at Risk conservation Fund which will not help the environmental situation here in the Province of Ontario. At the expense of Species at Risk and their Habitats, the government seems to find it more important to cater to business interests than to help the environment that we all must pass on to future generations. The government claims that the Species at Risk Conservation Fund will help Species at Risk and their habitats but at the same time it allows Business Interests to go about removing them and their habitats by paying into a Fund which in the long run is not going to improve the survivability of life forms that are Species at Risk. Without proper Habitat, how can these life forms even exist? Here's what I see wrong with this proposal:

a) The Ontario Government claims to be open for Business and it is bent on removing as much environmental legislation as is possible to achieve this. It is interesting to note that in removing much legislated protection in the Endangered Species Act, that the Government is in effect replacing the legislation with the Species at Risk Conservation Trust - another bureaucracy.

b) By making authorizations easier, the Government is allowing Business interests to go about destroying Species at Risk and their Habitats by the simple process of registering and paying into the Conservation Fund thus avoiding the necessity of complying with regulatory requirements and agreements.

c) The Conservation Fund setup allows for Business interests to escape having to do environmental offsets which are intended to provide a benefit to a Species at Risk. The situation in place if the Conservation Fund is enacted, means that the benefits standard inherit in the environmental offsets disappears and renders Endangered Species legislation impotent, hence no protection for Species at Risk or their Habitats.

c) The human population in Ontario is growing and there is going to be Climate Change. Setting up a Conservation Fund does not take these two principles into account. There are 200 plus Species at Risk in the province and yet only 6 species are mentioned that might warrant the limited oversight of the Trust.
Having such a Trust exacerbates the damage to Species at Risk and their Habitats by encouraging the
elimination of both. Species at Risk and their Habitats will not be helped by after the fact mitigation when the elimination of them should not have taken place in the first place.

d) By allowing Business interests to walk away from the elimination of Species at Risk and their Habitats, the 200 plus life forms in the province may be increasingly threatened and endangered, some may even become locally extirpated and in the case of life forms indigenous to Ontario, there might be extinction.
So, elimination of Species at Risk and their Habitats is a risk that the Government seems bent on removing from the way of any Business interest wanting to carry on a project. That is not good.

e) How is the Species at Risk Conservation Trust going to be remain viable on its own without continued Government funding? How are agency costs to be recovered? To what extent will the taxpaying citizens of this province have to fund this additional bureaucracy? Will the taxpaying citizens of this province be
responsible for the overhead of the agency? How will the agency determine which of the 200 plus other
life forms that are Species at Risk be handled? Why will there be so little scrutiny and reporting by the agency? Why is there no mention of public commenting on anything the agency might do? I do not see anything pointing to answers to these questions in the ERO 019-2636 proposal or other documents.

I offer these thoughts:

1) Do not create an additional bureaucracy under the Endangered Species Act. It's not the right use of
taxpayer's monies.

2) Business interests must be held accountable for their actions if it results in the elimination Species at Risk and their Habitats. Eliminate a species and destroy their habitat and you cannot simply recreate what was. What do we say to future Ontarians? Is that all that we were capable of?
 
3) Human activities and climate change need to be taken into account for ALL legislation in the province of Ontario. I do not see that in this proposal. We can do better for Species at Risk and their Habitats by
not eliminating them and destroying their habitats. Business interests are people - too - and they must be made aware of that their actions may mortgage the future for future Ontario citizens by leaving them with an unsatisfactory environment. I am sure that no one wants an environment where there are no birds singing, no native wildflowers growing, no native fish swimming or a forest free of indigenous trees.

4) I see more problems by creating the Species at Risk Conservation Trust. It's another bureaucracy that creates more questions than it answers. I think that past and present Governments should have left the
Endangered Species Act 2007 as it was. Eliminating parts of it in 2013 and 2019 does the environment in Ontario no good. The Conservation Fund may be created. But, I see that by elimination of Species at Risk and their Habitats, Ontario is poorer environmentally and it will not be able to fully meet the coming change to climate.

I trust these comments will be read and respected. Thank you for the opportunity to comment!