I am strongly opposed to the…

I am strongly opposed to the proposed changes to the Endangered Species Act. These changes are extremely regressive and will add significant pressure on species that are at risk of becoming extinct in Ontario.

It is clear that the proposed changes will not benefit any species at risk, they have been made to benefit developers. The possible extinction of Ontario’s species is not worth short-term economic gain. We need to start making long-term conservation plans We are at a tipping point, and if we don’t immediately implement strict regulations to protect these species it will be too late for many. 90% of wetlands in southern Ontario have already disappeared. 90% of many species of songbirds have declined. 60% of wildlife populations have disappeared worldwide. This has all happened within the last 5 decades. Extinction is forever - it will be much more costly when the government of Ontario is scrambling to save species from the brink of extinction than it is to maintain the current laws that were made to protect them.

It is clear that the new provincial government has no interest in wildlife conservation, but Ontarians have the right to see these species protected. These species have the right to a habitat which they depend on for survival. We continue to exploit our resources for profit, and we continue to fail to give something back to the system that sustains us. Everything we have comes from the environment and we take it for granted. This new proposal is based on greed and there is no denying that. With these proposed changes we are talking about the risk of losing 200+ species to extinction. I can’t sleep at night knowing the threat that these changes may bring to our wildlife, our environment, and to our people.

To summarize, none of the proposed changes should be implemented - keep the Endangered Species Act as-is. I am an ecologist with a wealth of knowledge and experience in this subject and my comments should be considered.

First and foremost, do NOT allow developers and municipalities to pay money to opt out of the Endangered Species Act. Since when do we allow people to pay money to get out of the law? This is absolutely preposterous. Every single developer and municipality is going to take advantage of this, and this is going to be detrimental to species at risk all over Ontario. What is the sense in having legislation if you can simply back out of it? The money to be made by this is nowhere near the replacement value of the species that we will lose from development. Species that are threatened and endangered are in imminent danger of going extinct. If hundreds of development projects are to proceed without protecting these species, we will lose entire populations, and possibly entire species. Again this is an excuse to let developers do what they want so they can profit while the rest of the people and wildlife of Ontario suffer the consequences.

Maintain the current 3 month deadline for a new at-risk species to be added to the SARO list. It can take years to properly assess the status of an at-risk species. Some wildlife populations can decline rapidly, and by the time studies and assessments are complete, newly classified species can be at even greater risk. It is critical we act quickly to implement their protection.

Do NOT make changes to their geographic boundaries. This is a provincial piece of legislation – populations outside Ontario should not be considered during assessment. This is only an excuse to limit protection and to prioritize development.

Leave COSSARO qualifications as-is. Non-scientists should not be making scientific decisions. These decisions should only be made by experts who have proper knowledge and training in ecology and biology. I would never diagnose a person’s medical condition, because I am not a medical doctor. Why would someone who is not an ecologist be deciding when a species is threatened?

Maintain automatic protection for threatened and endangered species. Do not implement a three-year waiting period for protection. Currently, the ESA classifies a species as “endangered” when:

“A species shall be classified as an endangered species if it lives in the wild in Ontario but is facing imminent extinction or extirpation.”

Facing “imminent extinction” means protection must be implemented immediately. Irreversible damage can be done in three years, and endangered species can go extinct during this time if proper protection is not applied.

Maintain the timeline and requirement to develop a habitat regulation proposal for each new listed species. Species have evolved separately and each species has unique habitat requirements. Some species’ habitats may overlap, but no two habitat requirements are exactly the same.

The Minister should not be able to use discretion to extend deadlines. These deadlines are put in place so important issues are dealt with promptly and are not swept under the rug or forgotten about. Again, this is just an excuse to delay the protection process so developers can carry on with work and the protection of species can be ignored.

Do not allow permit holders to operate for 12 months when a new species is listed. If a development project threatens a newly listed species, activities should stop until permits are amended. Again, threatened and endangered species are at imminent risk and all precautions should be taken to avoid habitat destruction or mortality. The death of a few individuals can be detrimental to the population.

Do not shift focus from “individual members” to “species”. A species’ population is made up of individuals, and if we don’t protect the individuals, we are not protecting the population or the species. For some species, such as Blanding’s turtles, the mortality of a few individuals can wipe out entire populations.

These proposed changes will be detrimental to populations of species at risk if they are to be approved. As Ontarians, we are lucky to live in a province with such unique and diverse habitats. We should take every step possible to protect them so they can be enjoyed by future generations. The impacts of the decisions we make today will last a lifetime. Why wait for things to be too late when we can take the right steps now? How will you feel when your grandchildren ask you about wild animals that they will never get to see in the wild? Will you feel proud to tell them that it was that so some rich people can make extra money? Because this is exactly what this proposal is. Make the right choice – do not proceed with the proposed changes to the Endangered Species Act.

Thank you for your time