I am strongly opposed to the…

I am strongly opposed to the direction that the discussion paper for the 10th year review for the Endangered Species Act is taking.

Business and industry cannot be allowed to proceed regardless of the ecological costs. Once habitat is fragmented or destroyed, we cannot bring it back. Many species depend on well-established, large expanses of mature forests, wetlands, tundra, or grasslands. Once that habitat no longer exists, species that are unable to adapt or migrate are destined to go extinct.

It is not possible “to improve protections for species at risk” and “streamline approvals and provide clarity to support economic development”. A Species at Risk instrument must fully prioritize species at risk.

Area of focus 1:
“protection and recovery approaches for individual species can limit or conflict with one another.”
When species naturally coexist, protecting habitat for multiple species cannot possibly conflict. When a conflict occurs, such as between wolves and woodland caribou, it is the fault of human interference in the form of resource exploration and extraction.

Area of focus 2:
“There is not enough public notice before a new species is automatically listed on the Species at Risk in Ontario List.” That is not true. Providing notice without first protecting species provides a warning that allows individuals, business, or industry with an intent to develop land the opportunity to destroy habitat and remove the species. Once the species has been removed, there remains little reason to prevent the development from going forward.

“In some cases, automatic species and habitat protections can contribute to high uncertainty and costly impacts to businesses and the public.” There should be no uncertainty; habitat preservation must come first. Worrying about costly impacts to business is short sighted. Consider the valuable ecosystem services provided by intact habitats over long time frames.

“longer transition periods or ministerial discretion on whether to apply, remove or temporarily delay protections for a threatened or endangered species, or its habitat.” This appears to give a minister license to ignore the scientific studies in favour of whatever development the government chooses to favour. Would you delay protection until there is nothing left to protect?

Area of focus 3:
9 months to develop a response statement and reviewing progress within 5 years is not too short a time frame. If it is legitimately a challenge to respond within 9 months, consider hiring more staff who have expertise in the required areas. Reviewing progress within 5 years allows further changes to be made to respond to continued declines, stability, or growth in populations. The sooner successful strategies are recognized, the sooner they can be duplicated in other areas.

Area of focus 4:
“in lieu of activity-based requirements enable paying into a conservation fund dedicated to species at risk conservation.” It needs to be recognized that after some development, there is no amount of money that can replace what has been lost. Alberta has discovered this with their huge sacrifice zone of the oil sands. There has been no evidence put forward that demonstrates companies have any ability to remediate any of the region, yet developments are approved with the promise of unproven rehabilitation. Large-scale developments such as the Ring of Fire have the potential to create a widespread sacrifice zone in Ontario. Many smaller developments together contribute to significant ecological declines. Allowing companies to pay into a fund without being directly responsible for action planning allows them to profit and walk away. Clearly governments, conservation authorities, and private organizations are not funded well enough to make up for this negligence.

In conclusion, please prioritize the species and habitats that are at risk. The legislation should not be seen as burdensome roadblocks. It should be seen as a safeguard for our collective future.