I am a citizen of Ontario…

I am a citizen of Ontario who values biodiversity and protecting endangered species. I do not believe that the proposed changes to the ESA will properly provide the protection needed for the endangered species of Ontario. I do not support the changes that are proposed to the ESA.
I have particular concerns with the following proposed changes:
1. The Minister can decide to suspend protection action for up to three years based on social and economic considerations, and decisions on these delays would be without public consultation, allowing those with political connections to undermine species protections without anyone knowing.
2. Companies can pay into a fund rather than fulfilling on-the-ground compensation for destructive activities that harm species at risk. If a species and its habitat is lost, than the species is lost. Putting money in a fund does not make up for this.
3. Opening up COSSARO to members without a science background is unacceptable. Decisions for placing species on the endangered species list should be founded in objective facts based on science, not from a subjective point of view.
4. Just because a species has healthy populations in other parts of its range outside of Ontario does not mean it should be discounted for protection if it is suffering within Ontario. “Edge-of-range” species are of equal value to any other and add to Ontario’s total biodiversity.
5. Giving the final say for a species listing to the Minister is wrong. The Minister is not a trained environmental scientist. The Minister should not have the ability to require COSSARO to reconsider their listing, when COSSARO has the most informed opinion. This would slow the process of listing.
6. MECP proposes to create “landscape agreements” for proponents undertaking harmful activities in multiple locations. Such an approach does not lend itself to addressing site-specific or species-specific concerns and consequently presents unwarranted additional risk for species already in peril.
7. The Minister would be able to limit ESA protections so that they apply only in specific geographies or under specific circumstances. This could exclude important habitats and species from protection.
8. MECP wants to allow projects approved under other laws to not also have to be approved by the ESA, allowing forestry and other industries to have exemptions from the ESA.
9. The new proposal would delay the listing of species to 9 months after assessments are public. This is much too long and species could be significantly harmed in this time period.
The ESA needs to make sure species listings are based on science, and avoid the input of biased parties. It needs to have listings be efficient and implementation of protection be strict. We do not need to revise the law, and deregulate. We need to improve the implementation of the laws.