Regarding changes to the…

Regarding changes to the assessment process, I support “Amendment E”- the proposal to consider a species condition around its broader biologically relevant area. However, this recommendation would better reflect societal values if it included the recognition that species can have regional significance. For example the trillium flower is Ontario’s official plant. It would be a loss to our Province if this species were to go locally extinct, despite remaining abundant in the USA or Quebec. Such cases could be accommodated with some kind of provision that balances broader biological considerations with the possibility of regional significance.

I see no reasonable justification for the extension from three to twelve months of delay before listings are reported and the time when they are enacted. At the same time this could result in irreversible harm to severely endangered species.

Concerning the proposed changes to implementation, Amendment A which allows Ministerial discretion to override COSSARO designations for up to three years could easily lend itself abuse. For instance a Minister with political motives could forestall a conservation decision in order to please a minority interest in his or her riding. Moreover, the proposal to make such discretionary decisions contingent on the Minister’s judgment that there are “significant social or economic implications” is overly vague and subjective. I am thus strongly opposed to this amendment.

Regarding the proposed amendments to permitting, I am opposed to all of the proposed changes that remove the requirement of the Minister to consult with experts. We expect our elected officials to make informed decisions that are in the best interest of society as a whole. Drawing on the relevant expertise is the most reliable way to ensure such outcomes. I can’t think of any societal benefit that would result from a loosening of the current consultation requirements.