Commentaire
I am not in favour of this proposal. I think that if this proposal is passed that the Endangered Species Act will fail to protect the species it is designed to protect and it will have no positive environmental outcomes. The following is why I think so:
i. There is no benefit to prolonging the time that the Minister has from receiving the COSSARO report to adding the species to the SARO List. If COSSARO believes that the species population is declining, it is better to act fast rather than slow so that habitat and individuals are not lost. It is of more environmental benefit to protect rather than attempt to rebuild habitat that's lost while the Minister acts slowly.
ii. If COSSARO believes the species should be listed, the Minister should not have the power to suspend the species and habitat protection for up to 3 years. If additional time is required to determine the best approach to protect the species and its habitat, it can be done while it's protected. There's no benefit to the species to allow it's habitat to be developed or for the species to be disturbed should the criteria be met for the Minister to pause the protection. Once the species habitat is developed or the species is disturbed, there is no undo button. For example, if we find out after development of the species habitat that COSSARO was right asking for the species to be protected, then this Act failed the species.
iii. Developers should not be given the option to pay a charge in lieu of completing certain on-the-ground activities required by the act. No amount of money will recreate habitat to a species liking or un-disturb a species. Biota is finicky and unreasonable. Just because the habitat looks the same as before, doesn't mean the species agrees. Biota also doesn't have a concept of money. You can't pay a Blue Heron to be okay with machinery operating close to its nest- it will abandon the nest.
Soumis le 16 mai 2019 11:12 AM
Commentaire sur
Examen décennal de la Loi de 2007 sur les espèces en voie de disparition de l’Ontario : Modifications proposées
Numéro du REO
013-5033
Identifiant (ID) du commentaire
29267
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