To address the proposed…

Numéro du REO

013-5033

Identifiant (ID) du commentaire

28690

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

To address the proposed changes, I have listed my comments using the same notation as the ERO page.
1)
A/B] The current timeline from COSSARO reporting to the Minister/SARO List, of three months should not be extended to 12 months. The added 9 months introduces the possibility of further damage by contractors and builders looking to hurriedly build in Endangered Species' habitat. The Act should remain as follows: "Within 3 months of receiving the report from COSSARO, the Minister must add the species to the SARO list. As soon as the species is added to the list, the Endangered Species Act immediately prohibits the killing, harming, harassing, etc. of species that are endangered or threatened and also prohibits the damage and destruction of their habitat."
C] If the COSSARO is required to submit their annual report to the Minister only between January 1-31 of each year, many species will have to wait until the following year to be added to the list. Basically your 12 month timeline becomes 24 months! This is unacceptable. January 1-31 is in the middle of winter. Surely no valuable information can be obtained on any non-arctic species in the middle of winter in Canada! Species evaluated in their appropriate life-history season will not get the protections they need until much much later - this is unacceptable.
D] By suggesting the Minister can require COSSARO and scientists to reclassify a species based on "their opinion" is irresponsible. Ministers are elected politicians, not likely to be scientists. What is meant by "scientific information"? Is the Minister going to be reading peer-reviewed journals? If so, how likely are those studies to have been conducted in Ontario, and how applicable are the findings if not conducted in Ontario, and will the Minister have the capacity to interpret that? Leave the science to the scientists.
E] This point is ridiculous. You cannot use abundance data from other populations outside of Ontario to assess the endangered status of species within Ontario. It's foolish, and would be akin to saying "well, we have a pretty good captive population of Polar Bears in the Toronto Zoo, so we're going to take them off of the SERO". Of particular concern to this point are migratory animals such as birds and fish.
F] Great, this should be applied across politics in general! Ministers should have the appropriate experience in the field for which they oversee. Eg. Education, Veteran's Affairs, Indigenous Affairs etc.

2)
A] So your plan is to make sure scientists conduct the assessments, but then you're going to let the Minister (with perhaps no scientific experience) have discretion on protections and veto-power? This is insane. A recommendation from the scientific community should be taken with more than "a grain of salt". Having criteria for suspending habitat and species protections for up to 3 years but failing to define "newly listed", as well as including an "other criteria as specified" category is literally the worst idea I've ever seen. Instead, let the scientists who conduct the assessments make recommendations on habitat and species protections. That would be the best idea, since they are the experts.
B] See 1E] and 2A] above.
C] What is the timeline? When the COSSARO submits their report the Minister, the Minister has 12 months to add the species to the SARO list, but how long to develop the species and habitat protection plan? This is vague and worrisome. Especially since you've used wording such as "geographies" which relate to my comments on 1E] above.
D] No. The Minister will most definitely NOT be qualified to make species-specific habitat regulations. Allow the COSSARO scientists to make recommendations and have the Minister select one of the options.

3)
A] Extend the timeline to what? No. Don't change the 9-month development timeline
B] Sure. But all policies moving forward should explicitly state "on recommendation from scientists in the field...".
C] No. Let the scientists evaluate the progress and provide recommendations to the Minister based on species status and recovery progress. The review timeline should remain unchanged (within 5 years)
D] I don't know what you mean by "posting", but public access to information sounds good.

4)
"Ontario is also proposing to create Canada’s first independent Crown agency proposed to be called the Species at Risk Conservation Trust, to allow municipalities or other infrastructure developers the option to pay a charge in lieu of completing certain on-the-ground activities required by the act. The funds would support strategic, coordinated and large-scale actions that assist in the protection and recovery of species at risk"
NO. FULL STOP. This Conservation Trust idea allowing developers to pay money to circumvent actions and conservation activities required by the ESA will be catastrophically damaging to species at risk in highly sought-after areas. For example, the Carolinian Prairie Grassland and Forest habitat in Southern Ontario between Tobermory, Toronto and Niagara Falls is home to many endangered species and is itself one of the rarest ecosystems in the world. It is highly sought-after for real estate and industry (ie. farming) because of its fertile lands, and in fact 7 million people already live in it! Allowing developers to pay an up-front fee in lieu of conservation efforts would allow them to profit in the long-run and exploit this area's delicate and finite resources. Unacceptable. If you do this, you can expect MANY more environmental protests in regards to building projects such as the Niagara Falls "Riverfront Community" project.
A,B,C,D,E,F] No, to all. No special work-arounds! Everyone must adhere to the current ESA.
G] Assuming the Minister is qualified, sure. But see my above comments relating to Minister duties 2A]

5) "minimize social or economic impacts", so what? - We are ALL stewards of Earth. There is no point in economic profit in the here and now unless there is a future to look forward to. What we need to do is to work together and find a solution that promotes sustainable growth. Economic, social, environmental sustainability now, to protect and preserve the environment for future generations. If we took all the money we've wasted in the last 10 years on arguing with one another over policy for the energy sector or smear campaign ads (Ontario's anti carbon tax ads costing us $30 million?!) and instead invested it in renewable and sustainable energy and technology research, imagine where we'd be as a nation and province! We'd be a world leader in conservation, sustainability and renewable energy. Canada would be GREEN, red and white. That's the Canada I want.