This posting says the…

This posting says the purpose of “Bill 5 is to support faster development by speeding up provincial permits and approvals to help Ontario’s industries thrive” and that “the SCA (Species Conservation Act) will continue to provide protection for species at risk and their core habitats,” however, I don’t see how both of those together are possible with the definitions and regulations proposed in the SCA. It seems that it is really only about speeding up development and removing the requirements that would protect species at risk in Ontario, which am very much opposed to.

First of all, as was brought up by many during the comment period for Bill 5 (and promptly overlooked, despite 61000 comments), the definition of used in the SCA habitat is unscientific. Scientists around the world define habitat as the Endangered Species Act had: “an area in which a species depends directly or indirectly to carry out its life processes.” Habitat is not only the area where a nest, dwelling, or root system is and the “immediate area” surrounding. The ESA also included areas where species at risk used to exist or where species can re-establish. This is important to include in order to avoid species going extinct or extirpated (in this case, meaning gone from Ontario).

The following are my comments on the specific proposed regulations:

1. There should be no changes to the list of species at risk. They are on the list because scientists are monitoring them and have found that if we do not do anything, they will eventually not be here anymore. That includes species of special concern, which scientists closely monitor. In addition, removing the species protected by the Federal Species At Risk Act makes no sense. According to the Canada-Ontario Agreement on Species at Risk (2011), “Canada and Ontario are committed to working together, and with
other jurisdictions, levels of government and partners to prevent species from
becoming at risk and to protect and recover species that have been identified as
being at risk.” This means that both levels of government have to work together to prevent the loss of species. Removing species at risk from the list is contrary to this agreement. In addition, the SCA should still include the requirement for species recovery strategies. I completely disagree with the removal of these as they are what guide both projects and conservation and would certainly go against the Canada-Ontario Agreement on Species at Risk and the Accord for the Protection of Species at Risk.

2. I don’t agree with a simple online registration. This could lead to registrants submitting bias reports on how their activity would affect species at risk. I notice that definitive language is used for the registration portion but anything regarding what could potentially help species at risk uses words like “may.” For example, it says “registrants may be required to work with qualified professionals to develop site-specific conservation plans that include actions to avoid or reduce impacts on species and their habitats,” which should not just be “may be required,” but actually be required to work with qualified professionals to avoid things like bias plans that would only benefit the registrants. In addition, under the “Specific requirements” section, non-definitive wording is used again, but these should all be absolutely definitive and required.

3. The permit regulation needs to have terms and conditions that are enforced and specific strict limitations on when permits are acceptable and how (e.g. no permits of any kind allowed during a species breeding season).

4. For the “Exception Regulation,” there should be no exceptions to any activity that would endanger the survival of a species. Ontario should want to protect the species that make Ontario unique. Ontario’s nature is a major attraction for visitors. Tourism from Ontario’s nature is a major part of our economy too and should be valued and protected.

5. Current activities should not transfer to the proposed registration, permit, or exemption because the definition of habitat proposed in the SCA is not scientifically accurate.

6. Ontarians deserve the right to a healthy environment for us and future generations. This is our home. The environment, including all of Ontario’s species at risk, is part of that. Therefore, the Regulations in the Environmental Bill of Rights should absolutely not be changed.

These proposed changes make me want to leave Ontario because I don’t want to watch my home and all the beautiful species that that also call this province home destroyed and paved over. Please reconsider these proposed changes.