I am a member of a wetland…

I am a member of a wetland ecology research lab at an Ontario university, though more pertinently I am a concerned citizen. I am concerned that the revision of the ESA will result in politicization and loss of protections for endangered species in Ontario. Protecting species diversity, including those currently endangered, across Ontario is vital to the protection of our ecosystems which not only provide ecosystem services like groundwater quality but also represent the identity of Ontario as a biologically diverse ecosystem. After consulting literature produced by the Environmental Commission of Ontario, I have a few points I would like to bring to your attention:

The proposed changes to the listing of species would politicize a process which should be completely and only based on scientific evidence as concluded by COSSARO, not finally on the discretion of the minister who may not have a sufficient scientific background and thus would be unqualified to make such a determination. Further, requiring COSSARO to consider a broader geographic range in the listing of species is misguided. Species which may be abundant and prospering in an area outside of Ontario could be threatened within Ontario, though this does not mean that these species are not to be protected within Ontario. All species do provide services and it is important to maintain local diversity within Ontario, regardless of their broad distribution.

Removing the immediate automatic protections on species listed by COSSARO is a misguided decision. Species on the list do need these protections because they are already in danger of population declines in the status quo. By enabling the minister to suspend action, they threaten the species with extinction. Furthermore, the criteria for which the minister would be allowed to leverage to suspend action is not scientifically based and goes against the purpose of the ESA: to protect endangered species at all times, not only when it is convenient. More so, by giving the minister discretion to extend the time for which the government has to develop a recovery strategy only allows for the continued damage to endangered species habitat. The minister is unqualified to make such decisions.

Lastly though possibly most importantly, the proposed changes to the act would allow for violators of the ESA to simply pay a mere fine, despite this being contrary to the mission of the Act, instead of using that money to comply with the conditions specified in the act. Further, the changes remove the requirement for consultation of independent experts, which is contrary to the act's important dedication to science based conclusions.