The direction that the…

The direction that the Ontario government is taking with these proposed changes to the Endangered Species Act is reckless, irresponsible and will weaken Ontario's commitment to protecting endangered species. Every suggestion in these proposed amendments weaken protections of endangered species, so I do not support any of them, but below are comments on a select few.

When a species' is listed in Ontario they are typically already in a perilous state. This means that immediate action is required to keep populations from declining further - the amendments to the ESA completely undermine this tenant of conservation. Extending the time between the Minister receiving a COSSARO report and said species being listed from 3 months to 12 months is an unnecessary delay that will result in far more species becoming extirpated in Ontario.

These proposed amendments result in too much discretion being given to the Minister. Allowing the Minister to require COSSARO to reconsider classifications of species is irresponsible, made more so by the fact that species that are not listed or are of special concern cannot be added to the SARO list or listed as a more endangered status. This is blatant in that it allows the Minister to undermine COSSARO decisions and reduce protections on species at risk.

The Minister is not a trained scientist - without background in conservation, species at risk, ecology or a similar discipline they are not qualified to make decisions regarding the preservation of species at risk.

Canada, and Ontario specifically, does not exist in a vacuum. Due to the effects of climate change, connectivity in a species' Northern range may prevent said species from becoming extinct. Species should be assessed based on their range within Ontario only, regardless of their population size or expanse elsewhere.

There is *absolutely* no reason that the process of habitat protection should be de-coupled from a species being listed as at-risk. This again is an opportunity for business and development to over-ride the needs of our most vulnerable species. If a species has been listed it is, again, in need of immediate protections. There is more to be lost if protections are delayed, for any of the reasons listed in 2A i - iii, than if protections are immediately put in place. Extending or removing mandatory timelines is a recurring theme throughout these proposed changes. This sends the message that Ontario does not care about preserving our unique environment or the species that call it home.

Finally, in lieu payments for not following protections/regulations/guidelines etc. have never been an effective way of balancing business interests and native species. There is ample evidence from within Canada and the US where payment does not lead to the creation of equivalent habitat or offset habitat loss. Currently we know the OMNRF has often permitted exemptions for activities that violate portions of the ESA - what is required is stronger enforcement of the current Act.

These changes are, across the board, a weakening of Ontario's commitment to being a leader in conservation. In a world where we understand the value of nature and the invaluable services provided to us by intact ecosystems it is irresponsible to weaken environmental protections.