Many of the proposed changes…

Many of the proposed changes will have detrimental effects on Ontario's species at risk. It is critical to ensure that in making decisions, the safeguarding of these sensitive species is top priority - overall biodiversity, and in fact many individual species at risk specifically, have huge impacts - both direct and indirect - on humans in a social, health, and economic sense. Therefore, while it may seem intuitive to prioritize humans having to change as little as possible within this legislation, the resulting damage to society will be far worse.

The purpose of listing and enacting protections for species at risk within the current time frame is to ensure rushed, "last minute" actions with adverse effects are not taken. Extending this window does not help - in fact, it encourages a mindset of "how much time you have left to act a certain way" rather than simply learning to act better because you have to. Similarly, increasing length of notice for these protections is the same - this is specifically significant for species that may be listed as at risk because of hunting and poaching. Larger "reminders" or "notices" essentially provides a timeline to say "get as much as you can now".

As someone who studies ecology, I know firsthand that the natural world can be unpredictable and it runs on its own timeline, not ours. Therefore, it is essential that ecological issues, especially those as significant as species at risk, are protected and acted upon as quickly as possible - ideally, as soon as you realize something is wrong. By making all new listings occur within a set time frame, this significantly reduces the response time. Ecology requires a fine balance; as more time goes by problems get exponentially more difficult to solve, sometimes becoming completely irreparable. As such, immediate protection of all listed species is essential. Moreover, the Minister, who may or may not know ANYTHING about ecology or a given species, should not be able to simply suspend a species' protection. This, along with giving the Minister authority to extend deadlines for SAR listing or publications is only opening the window for the continuation of harmful actions that threaten the specific species. Again, time is a significant factor, and it does not make sense to "suspend" the protection provided by the listing unless the species has recovered substantially enough to be considered a healthy, self-sustaining population to the point where it no longer ecologically makes sense to have them listed. It is not reasonable to go off of the criteria that suspension of protection will not have adverse effects on it's survival within Ontario, as obviously there are threats to its survival in Ontario which have led to its listing in the first place.

Additionally, the entire purpose of the SAR listing is to provide protection to these species through the ESA and scientific research. To remove these protections, whether literally by allowing some species to be exceptions, or indirectly by making it easier for companies and individuals to be able to dismiss or forgo them completely negates this purpose. Species at risk require our protection - often because of the actions that we seek to continue; only once a species is recovered should these limitations be lifted. While of course it is essential to protect individuals of a species themselves, it is also extremely important to protect their habitat. It is very ineffective to displace or relocate species and alter or remove their former habitat - although it "protects" the species, more often than not it just kills them more slowly, as they will instead die of lack of resources, disorientation, or in trying to return to their former habitat. Many species have excellent homing ability (the ability to get themselves back to their home/habitat) and high site fidelity (meaning they consistently return to the same location for things like hunting, overwintering, breeding, etc). Again, this means that in protecting a species, it is critical that their habitat is included and should not be subject to additional lenience when enforcing the act.

When it comes to exceptions for following the ESA, the proposed amendments are essentially short-cuts for companies to ignore protected species. There should be MANDATORY consultation with approved expert consultants in regards to a complete list of all relevant species and how each of them will be affected - importantly, this should NOT, under any circumstances, be able to be overruled by the Minister. There is no reason to forgo this step. Additionally, money is not an acceptable replacement for adverse affects on sensitive species; all permit holders that are determined to need to continue acting despite possible or known harm to a species at risk should be required to provide suitable alternative compensation for that species as approved by relevant consultants. This could include alternative habitat, alternative site restoration, or other actions as appropriate.