The proposed changes to the…

The proposed changes to the Endangered Species Act include a few notable positive changes, such as requiring annual status updates. However these are marred by the numerous glaring negative aspects that will put endangered species in Ontario at greater risk of extinction:

Point 1E:
“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.”
- This regulation disregards the very real impacts of local population extinctions. Species require adequate habitat and connectivity of smaller populations in order to sustain the overall population. Ontario is a link in this chain, connecting the United States and Eastern and Western Canada. By accepting this regulation, Ontario would be shirking it’s responsibility for environmental stewardship on the pretense that others will pick up the slack.

Point 1D, 2A-D, 3C, 4A, 4D
- Altogether too much power is given to the individual minister. Decisions made by a committee of scientists should not have the power to be overthrown by an individual public servant. A committee is less likely to be biased, as ministers face pressure to adhere to the interests of their party and are likely to be replaced if they disagree.

Point 2A
- These regulations are entirely contrary to the actual goal of protecting species at risk
o Decoupling automatic protections essentially allows bureaucracy to tie up the process of protecting species. This is already an issue, with many species on the list still lacking any sort of plan for their protection
o Suspending protection for species to allow for “additional time to address the primary threats” is inherently logically inconsistent. Addressing primary threats should be a priority, but while plans and research are in development, a species should still be protected.
o Social and economic implications should not outweigh environmental considerations. To say that temporary suspension will not jeopardize the survival of the species is extremely short-sighted at best and impossible to prove. Furthermore, this is irrelevant if this species is already being considered under Cossaro – the implication for consideration is that the species has been impacted. Further inaction will not allow the species to recover.
o Extending timelines will again continue to put species that require protection at additional risk of experiencing further decline. This is already an issue in current reviews of endangered species

Point 2C
- Similar to point 2A, this legislation flies in the face of species conservation. Historically, suggested best practices are ineffective. Protection of Habitat MUST be a priority. Species cannot exist without appropriate habitat

Point 4
- The pay-to-slay legislation is outrageous. On the ground actions are vital and necessary to the protection of species. In recent ads, Ontario has talked about keeping the worst offenders accountable with regards to climate change – this change in species at risk legislation expressly exempts the worst offenders from any responsibility towards mitigating their environmental impacts