On behalf of my entire…

On behalf of my entire family who live and vote throughout Ontario, I am writing to express our concerns about the government's proposals arising from the review of the Endangered Species Act.

We agree that changes are needed to the Act. However, we are puzzled about how these proposals will strengthen protections for wildlife. What are we missing? We see how applications under the Act may be "streamlined", but could you please explain what is being proposed to STRENGTHEN our province's PROTECTION FOR WILDLIFE? From what we have been able to read/find, we are left with the distinct impression that these proposed changes will weaken the Endangered Species Act and make it easier to destroy critical wildlife habitat. We already have been personally observing such disturbing and destructive practices in our area and in other regions across Ontario.

Specific major comments/concerns follow. (Words in CAPITALS are for emphasis.)
• Numerous proposals will lengthening timeframes or introduce delays to the start of protections for Species at Risk and their essential habitats. How can this possibly “strengthen” our province’s protection for wildlife? Please make revisions to the following -- in order to REDUCE delays and actually IMPROVE PROTECTIONS: Proposal 1. Assessing species at risk and listing them on the Species at Risk in Ontario List, proposed changes A & D; Proposal 2. Defining and implementing species and habitat protections, proposed changes A [option to suspend species and habitat protections for up to three years; require that all criteria in iii be met – not just one] & C; Proposal 3. Developing species at risk recovery policies, proposed changes A & C re extending timelines; and Proposal 4. Issuing Endangered Species Act permits and agreements and developing regulatory exemptions, proposed change C.
• The approach of REQUIRING the Committee on the Status of Species at Risk in Ontario (COSSARO) to “adjust a species’ classification” based on its overall “condition around its broader biologically relevant geographic area, inside and OUTSIDE Ontario” seems very short sighted [proposal 1-E]. It is known that often wildlife corridors have been disrupted by human activities and have left species cut off. However, the genetic diversity offered by even a small population may be vital to long-term survival of the species.
• Creation of Species at Risk Conservation Trust has considerable appeal and would meet a need. However, we suggest this be used when individuals or organizations have not been compliant with the regulations. We live on the Bruce Peninsula and we see this happening all around us as precious habitat is destroyed for "development" (forestry, quarries, housing). There seems to be little penalty for such disregard! The current proposal to use this proactively will need wisdom and information about impacts that may be beyond reach. We risk the loss or irreparable damage to ecosystems that cannot be "forgiven" or replaced.
• Greatly expanded powers for the Minister in some situations seem to risk overreach and potential interference, rather than effective and appropriate oversight and action. Relates to proposals 1D, 2A&D, 3A&C, 4 A&F. Suggest these be removed or greatly revised.

Biodiversity in Ontario and Canada is under extreme pressure -- largely from habitat loss and degradation (and invasive species often associated with development and roads). Indeed, the recent report of the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) provides a chilling summary of a global problem! We in Ontario need to do our part and follow a precautionary principle regarding species and habitat protection. The current proposed changes to the ESA fall far short on that count.

We urge you to do what you can to give vulnerable species a chance at survival -- not make it easier for them to be eradicated by destroying vital habitat. The previous government already relaxed regulations and this resulted in a surge of "approved" developments. How will this be better controlled by your proposals?

In our opinion, the Endangered Species Act needs to be strengthened by doing the following:

1. Institute an approach that truly protects species and their habitats by removing many of the potentially harmful exemptions that degrade and fragment critical habitat.

2. Work with local governments and conservation groups to develop meaningful local approaches to habitat and species protections – and provide financial assistance when needed.

3. Maintain a strong voice for science and evidence, including aboriginal traditional knowledge, in the implementation of the revised Endangered Species Act.

4. Reconsider the proposal of allowing habitat degradation in exchange for contribution to a fund. Research and better understanding is needed, we agree, but not at the expense of destroying critical habitat that can never be replaced or "moved"!

5. Do not remove threatened species from our Ontario list just because they are "plentiful" somewhere else. It is known that often wildlife corridors have been disrupted and have left species cut off. However, the genetic diversity of even a small population may be vital to long-term survival of the species.

We urge you to take actions to help ensure the survival of endangered and threatened species throughout our province. The disappearance of any of these species may have profound negative impacts that we simply do not appreciate at this point. The time to take a precautionary approach is NOW!