As a lifelong resident and…

As a lifelong resident and taxpayer of Ontario, I am dismayed by many of the discussion questions proposed by the Ontario government as part of the 10th year review of Ontario’s Endangered Species Act.

In this discussion paper, there is a clear emphasis on trying to reduce the level of protection provided to SAR in favour of economic development (e.g., generalization of habitat protection whereas many SAR require specific habitat sizes/features etc.). Changes to the Endangered Species Act should improve SAR protection and foster population stability and recovery, not weaken and further endanger their survival it appears to be the direction of the review as indicated in the discussion paper.

It appears also that this review also will not address exemptions that enable business and industry to impact habitat considered critical. If efficiencies for business is desired, one thing that business responds to is clarity, and so clearly defined no-go zones to protect wildlife and wildlife habitat where development won’t be permitted would be an excellent addition to a revised Act.

The stress on SAR, with increasing human population concomitant with poorly planned or weakly regulated land use planning/development, as well as current regulated but in some cases poorly enforced (due to lack of enforcement capacity) environmental pollution or habitat degradation regulations, is increasing exponentially in Ontario. Ontario has the highest biodiversity of all of Canada in the most densely populated area, and the biggest stressor to SAR populations is loss of habitat.

Aside from the intrinsic value of wildlife and wild places to the people of Ontario, there is enormous economic potential and advantage to protecting and restoring natural habitat for SAR species including: drinking water protection; improved air and noise quality; decreased light pollution; recreation (passive and light active); and, finally, in one area that represents the most costly portion of Ontario government spending – health care. This is because an increasing body of medical and psychological data is accruing that shows that protecting and restoring natural habitat (such as those needed by SAR populations), particularly in highly populated areas where developmental and industrial pressure is greatest, improves both physical and mental human health and thereby will result in significant cost savings by preventing and/or help treat acute and chronic physical and mental illness of Ontarians.

The above comments are applicable to all areas of focus especially 2-4, and I would like to include additional comments on Area of Focus 1:

Existing tools and processes that can be used include a rigorous cumulative effects assessment approach that documents and quantifies the incremental and total impacts of new activity or intensification of existing activity is recommended. This approach needs to assess, at multiple geospatial and temporal scales how SAR (sub)population survival, maintenance or recovery (if any) is impacted by activity during the entire lifecycle of a population (breeding, overwintering, feeding, etc., i.e., any stage of the lifecycle that is relevant to the population existing in Ontario). A true, robust cumulative effects assessment must consider activities and degraded habitat that has already occurred outside Ontario jurisdictions such as development along international migratory flyways, in order to understand the incremental effects of new activity in Ontario to a population. Landscape level assessments need to include, for example, total habitat area, connectivity of habitats and access to (or barriers to) important habitat features required by SAR. Too many assessments only look at isolated effects of a single proposed activity or development on a population, rather than the cumulative effect of said activity or development on a landscape already impacted by past land use/land activity changes.