Hello: I wish to provide the…

Hello:

I wish to provide the following comments on the proposed changes to the Endangered Species Act:

1. Assessing species at risk and listing them on the Species at Risk in Ontario List

- I find the proposed change to the timeframe between when a COSSARO report is received by the Minister to when the listing is to occur from 3 months to 12 months problematic. I find it problematic because it treats all species classification (i.e., special concern, threatened, endangered, etc.) as equal when they are not. A species classified as threatened or endangered is more deserving of attention in terms of quicker actions that must be taken to protect its survival as opposed to say a species classified as special concern. I would recommend that the 3 month timeframe be retained for species classified as extirpated, threatened and endangered and perhaps a longer timeframe for species classified as special concern. In short, retain the shorter timeframe for listing a species in the SARO list for those classified as extirpated, threatened, and/or endangered.

- The proposed change to allow the Minister to require COSSARO to reconsider the classification of a species where the Minister forms the opinion based on scientific information that the classification may not no longer be appropriate is troubling to say the least. While I understand that the Minister will be informed by scientific information, the Minister may not necessarily be a qualified scientist to assess the information and /or fully appreciate its implications. As such, I would recommend that the Minister NOT be permitted to require COSSARO to reconsider species classifications. Instead, let this work be done by the qualified scientists who sit on the COSSARO as I am sure they would if and when a species needs to be re-classified. There should be no political interference in the species classification process.

- I firmly disagree with the approach to require COSSARO to consider a species’ condition around its broader biologically relevant geographic area, inside and outside Ontario, before classifying a species as endangered or threatened. If the overall condition of risk to the species in the broader biologically relevant geographic area is lower, COSSARO would be required to adjust the species’ classification to reflect its overall condition. I would remind the government that the ESA is about protecting/ensuring the survival of species within Ontario's borders regardless of how the species may be faring in its broader geographical range. Species that are threatened and/or endangered within Ontario should not have their classification lowered since they should be protected throughout their range to ensure their long-term survival and well-being. Furthermore, species know no borders as they move throughout their range in search of shelter, food, mates and/or to nest. It is problematic to think that species could potentially be treated/valued differently depending on what part of their range they are in. For the long-term viability of a species, COSSARO should only assess the status of species within their range in Ontario to ensure their survival in Ontario as they are part of our natural heritage.

2. Defining and implementing species and habitat protections

- The proposal to remove the mandatory legislative requirement and timeline to develop a habitat regulation proposal for each newly-listed threatened or endangered species defeats the purpose and spirit of the ESA. For threatened or endangered species, it would seem vital to move towards developing a habitat regulation to ensure the survival of the species. Please retain the mandatory legislative requirement and timeline for the habitat regulation; it should not be optional.

4. Issuing Endangered Species Act permits and agreements and developing regulatory exemptions

- It seems contradictory for the government to propose the creation of the Species at Risk Conservation Trust to allow municipalities or other infrastructure proponents the option to pay a charge in lieu of completing certain on-the-ground activities required by the act but then still require them to fulfill some on the ground requirements to minimize the adverse effects on species. Would it not make more sense and be more cost effective to have the proponents undertake the on the ground actions rather than pay into a trust that has to be publicly administered? Furthermore, if the regulatory charge is to be within the range of costs that a client would otherwise incur through meeting the species-based conditions of an authorization, then why not have them just undertake the actions in the authorization instead complicating the process through the creation of a separate bureaucracy to administer the funds collected? This proposed change needs to be thought through further with its merits carefully weighed. The protection of species should not be something one can pay to ignore or dismiss.