I see a major problem with…

I see a major problem with this proposed Fund in that, while it is packaged as being for the benefit of wildlife, it is premised on the destruction of crucial habitat that species at risk depend upon for survival. The very presentation of this Fund as one dedicated to "Species at Risk Conservation" seems to me to be in bad faith in that allows the government a false guise of caring for the environment at the same time that it opens the door to faster and more widespread environmental damage.

This Fund will give developers clearance to proceed with activities that harm the natural environment and destroy species at risk habitat as soon as they pay into the fun. The simple act of paying a fee frees them from responsibility for the harm they cause.

The easier it is to obtain permission for activities that harm the environment and destroy habitat, the more likely such activities will occur. When in 2013 the government introduced sweeping exemptions for developers, for example, ESA authorizations for harmful activities "drastically increased," according to the Environmental Commissioner of Ontario (ECO 2017 report, p. 227). To focus in on the disturbing impact for just one at risk species, prior to these exemptions, only 2 permits had ever been granted for activities threatening harm to barn swallows, following the species' 65% decline between 1965-2009 due to habitat loss. Following the exemptions, 525 authorizations were given for activities harmful to barn swallows between 2017-2017.

I am alarmed that this fund will allow proponents of habitat-destructive activities harmful to the whip-poor-will and Blanding's turtle a quick and easy alternative to obtaining an ESA permit.

Equally alarming is the fact that there is no requirement for Fund monies to be used to compensate communities for negative impacts in the watersheds, municipalities, or Indigenous traditional territories.

I am also concerned that the Fund absolves those who harm habitat of liability. With permits and exemptions, those behind environmentally harmful activities are responsible for ensuring the compensating actions are implemented. The Fund formulas do not acknowledge the value added of developers being absolved of liability.

An additional serious problem is the Fund's lack of transparency and accountability. There is no requirement or expressed intent to publicly disclose information about the specific and cumulative impacts of the harmful activities undertaken by those paying into it. Without this information, the public will be unable to determine whether the Fund actions are commensurate with the level of habitat destruction caused by the authorized activities.

For all these reasons, I do not support the government's plan to implement this Fund. I am deeply concerned about the future health of our species at risk, our watersheds, and our air quality. This Fund will leave them vulnerable to destruction at the very time when they so urgently need increased protections.