As a resident of Ontario and…

As a resident of Ontario and a strong proponent of environmental protection, I am extremely opposed to the proposed changes to the Endangered Species Act. Ontario once had the strongest protections for Endangered Species in Canada, but the changes outlined in Bill 108, Schedule 5, would drastically weaken the protections for our most vulnerable species and prevent the ESA from efficiently protecting these species and their habitat.

I am specifically opposed to:

1. Changes that allow the Ministry to delay or withhold protections on whim without the input of external, qualified scientists;

2. Pushing back when protections kick in after soon-to-be-listed species are announced, which allows developers more time to knowingly degrade, damage, and remove the habitat used by listed species before protections legally begin;

3. Changes that no longer automatically protect newly listed species from existing developments and industry, and no longer automatically protect vital habitat;

4. “Scoping” of protections – with the vague wording used (“specific circumstances”), the Minister essentially has free rein to withhold protections on a whim; and

5. “Pay to slay” – instating a “Species at Risk Conservation Trust” to accept cash instead of actual conservation and restoration work currently required by the ESA. Replacement or restoration of original habitat is NOT as good as preserving original habitat, and should be a last resort. There is also no substitute for strong and enforced regulation, and accepting monetary compensation sends the wrong message on how little value the Government of Ontario and the Ministry of Environment, Conservation and Park place on Ontario’s unique, irreplaceable, and priceless Species at Risk. It is absolutely unbelievable that the Bill reassures the reader that payment-in-lieu would be “within the range of costs that a client would have otherwise incurred through meeting the species-based conditions of an authorization” – if we are willing to sacrifice Species at Risk for money, the regulatory charge should at least exceed the typical costs for carrying out conservation and restoration activities as a deterrent!

Additionally, many of the proposed changes are written using exceptionally vague language without concrete details or examples, making it difficult to understand how these changes would affect the process of listing and protected species under the amended Endangered Species Act. The vague language also seems to imply that many decisions will be up to the Ministry’s discretion, as the proposed changes would do little to curtail delayed or scoped protections based on specific interests.