Comments on the 10 year…

Comments on the 10 year review of Ontario ESA

Page 2, second column: it may be good to add invasive species as a threat to biodiversity and species at risk

Area focus 1
The ecosystem approach would be more effective when you have more than one species at risk in an ecosystem or an area. This approach has been promoted by DFO and Environment Canada and Climate Change for many years. However, you will still get push back from researchers with reductionist approach. Ecosystem approach as so means the need for more stringent policies for ecosystems, which Ontario has been weak. For example, wetlands are being destroyed as greater rate than ever, while it is well known they contain species at risk or uncommon species AND provide many essential ecosystem services. The advantage of ecosystem approach (which we promote at the Commission on Ecosystem Management, with its 12 principles) is that it responds to many other issues that species at risk and biodiversity are facing such as climate change and therefore potential migration of species. This also means looking at connectivity in landscape for better protection of these species. This would also mean stronger “green belts” or development of similar policies. There are ways to help with this such as better supporting Nature Trust and other such organizations or owners with conservation interest through conservation easements.

Area Focus 2
I would be careful in increasing time before listing a species. By the time it is done, the species may be extinct. The time is already long before a species can even be discussed. What is needed is a more transparent, open and inclusive communication process with not only a website that is difficult to navigate but also more locally focused activities and communication, including listservs for detection, information gathering, and call for development of assessment and conservation plan. These should anyway be more collaborative instead of being produce din closed doors.
I would avoid ministerial discretion as species shall not be entangled in politics. Species have no capacity to defend themselves (and should not be looked only for utilitarian purposes).
There are no circumstances unless you’re a politician or a business lobbying for a specific development (which we have seen too many): this should not be allowed. There are plenty of empty spaces that are always abandoned and should be looked at first. Stop using more natural areas. I know it may cost more for the developer but by the end, we may reduce the footprint of the province on natural habitats. You never know if that species could one day stop or cure a disease. Think about the yew and taxol.
The only way is to keep everything in open access (this is in fact required with any research…may want to see the UNESCO Recommendation on Science and researchers 2017, Canada supported it) to avoid political interference and closed-door lobbying.

Area Focus 3
Regarding additional time: I don’t think this is really needed. It would certainly not a benefit for the species. Again, is this politically motivated? If the system is transparent, open, with involvement of people (scientists, Indigenous Peoples, local nature groups, etc.), this should not be too much of an issue. Maybe an exception could be made in the case where more involvement and discussion with Indigenous Peoples are needed.
The 5-year review period is the normal system in most jurisdictions (federal, provincial and even most international). It could possibly be longer if there is a very good monitoring system in place and the species is relatively stable or in less risky category. BUT this would mean to be serious about monitoring and not only something done as a lip service.
This last point contradicts the ecosystem approach. Species don’t live in a bubble (only humans do). The idea that a species can just be move as desired is a false and unprofessional concept. As a species is integral part of an ecosystem, you cannot just take one and move to another place as it is impossible to recreate the same habitat. This has been known for a long time. Microorganisms in the soil may be as important as water or light.

Area focus 4
There are too many loop holes in the current system that lead to avoiding to protection. The best would be to reduce them. This is especially important close to urban centres. There is already not enough space for natural habitats in southern Ontario for example and close to urban centres. For developers (as the point is directly related to this), why not starting to teach them about intensification and the need to refurbish abandoned lands in urban centres. There are already too many of them. Stop building on newly cleared lands and start thinking about conservation easements in other places. This is especially important under climate change (to ensure connectivity for species) and population decline (without immigration population of Canada is declining). Some countries, like China, are more advanced than us on this. They have learned quite a while ago to better protect rural and natural places.
So, by the end, it seems that the government wants to find a way to avoid species conservation and just go for development (I feel like we were in the 1970’s!!). This ‘business-as-usual’ approach will put Ontario in the dark age when we consider how other countries are moving away from this type of way of thinking. All policies and legislation shall integrate environmental concepts, protections and conservation of biodiversity. This is in fact against how the federal government is moving with the new round of negotiations on the CBD.
What is needed is more money for ESA and especially enforcement of all related legislation such as the Wetlands Act.