The Wilderness Committee…

Numéro du REO

013-4143

Identifiant (ID) du commentaire

22964

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

The Wilderness Committee Ontario does not approve of the Ford government’s plan to review and change the Ontario Endangered Species Act. The changes proposed were not created with species at risk protection and recovery in mind. Rather, proposed changes would only allow more discretion to the minister and provide industry with more opportunities to destroy species at risk habitat, which will further contribute to extinction. The below paragraphs address the proposed changes and why these are a terrible idea for wildlife at risk.

1. The Ontario government wants to change recovery from case by case to a more broad approach which will be extremely harmful to species at risk recovery. Case by case planning identifies exactly which activities will harm the species and which activities should be avoided and where. Without this fine detail level of planning, protection of habitat will be vague and it will allow industrial activities to destroy once protected habitat for species at risk.

2. A “landscape approach” to migratory species at risk conservation will allow more habitat to be opened up for activities. It is clear the goal of this change is to increase industry activity within species at risk ranges. But there is no way to increase habitat destruction while recovering species at risk. The entire point of an endangered species act is to recover the species. In most cases, the reason for their decline is from human activities. If projects must be rejected or moved to an area of less disturbance than that is what must happen for species to recover. There is no way to open more habitat up for industrial activities and conserve more species — this is obviously an attempt to diminish the protection of species at risk and their habitat.

3. Landscape approaches will result in more species becoming at risk because more important habitat will be opened up for development and industrial activity. In order to avoid more species becoming at risk a case by case approach which protects habitat from industrial activity is the best option. If Landscape level planning is chosen, then the critical habitat of the species at risk must remain protected from development and industrial activities. Absolutely no species at risk recovery plan will be effective if the species habitat is open for destruction.

4. The only change that should be made to the ESA are closing the loopholes and exemptions that began in 2013. The Ford government must end the exemptions and loopholes open to industry, like forestry, that came into effect in 2013 which exempts these industries from following the Endangered Species Act.

5. All species at risk should be added onto the Species at Risk List. There should be no public consultation because it must be a science-based decision. No social or economic opinions should influence whether a species is at risk or not. Anything that allows socio-economics to influence this list will result in the entire law becoming not science-based and severely flawed. Socio-economics can come into the recovery planning later, but the species at risk list must not be influenced by socio-economic considerations.

6. Automatic protection to species and habitat must remain. The government must work to create action plans and once those are implemented the automatic protections can be removed. Without automatically protecting habitat industry will have time destroy this habitat before it becomes protected under a plan. This cannot happen and will destroy the integrity and successfulness of the law.

7. The government wants to extend the timeline to create response statements for an endangered and threatened species. Nine months is plenty of time and extending the deadline indefinitely will likely result in response statements never being produced.

8. The government states that 5 years from the response statement is too soon to review species at risk progress and recovery. Species at risk do not have 5 years for mistakes. We must ensure that the effectiveness of recovery plans are being reviewed as often as possible (at the very least every 5 years) so that we can adjust them if they are not working. If the government is having trouble meeting these goals, they should hire more staff.

9. The Ford government wants to speed up the authorizations and approvals of projects, which should not happen. They also want to decrease the number of requirements for companies wanting to harm a species or its habitat, this also must not happen. They claim that it is creating a barrier to economic development. A thorough review of projects is essential to any healthy environment and to wildlife. There is no way to save species at risk if more projects that destroy habitat threaten species are approved. Speeding up the time for approval and limiting requirements of the application will allow harmful projects to be approved. It will allow companies to be careless and there will no longer be a requirement for projects to avoiding or mitigate impacts to species at risk. The review process of an applicants project must be thorough because if it is sped up and carelessly approved, species at risk populations will continue to plummet. Projects that contribute to extinction must be rejected, plain and simple.