Re: Bill 108, Schedule 5 …

Re: Bill 108, Schedule 5 (ERO 013-5033) Proposed Amendments to Ontario’s Endangered Species Act

Ontario should be a leader among the provinces in Canada in saving endangered species. Extinction is forever. We now know that many of Earth's species will be extinct in the next decades if nothing is done to protect them. This is our watch. Please let’s not look back in 10 years and say, “On our watch, many of Ontario’s Species at Risk became extinct.” Ontarians don't want this. We want our children and grandchildren to have the same opportunities to see and enjoy Nature that we have had.

One of the main reasons that we are facing such a bleak future for wildlife is that we aren't adequately protecting the habitats of endangered plants and animals. The Ontario government can make a difference by strengthening, rather than weakening protections for wildlife and its habitats. Where wildlife flourishes, so do people. If we are to have a sustainable economy and society, we must maintain a healthy environment.

Endangered animals and plants can't speak for themselves. It's up to us to care for them.

Here's why I strongly oppose the changes that are being considered: They will not improve outcomes for species at risk. On the contrary, they would make it easier for industry and developers to destroy the habitats of our most vulnerable plants and animals. As you cut protections for wetlands, lakes and rivers, you destroy the homes of animals and plants. About 90% of all wildlife relies on the shoreline of water bodies for some or all of their life cycles.

I worry about basing protections on COSSARO assessments that would be based not on the status of a species in Ontario, but instead on its status throughout its range. For example, southern Ontario endangered species at the northern limit of their range may receive less or no protection, depending on their status outside Ontario. This is especially concerning in the face of climate change because healthy species populations are needed at their northern limits to help species adapt to changing climatic conditions.

The Environmental Bill of Rights posting and consultation requirements must continue to be applied to all habitats of species at risk if we are to have any hope of saving them.

I strongly oppose proposed changes which would introduce broad ministerial discretion to interfere with the science-based listing process, to suspend and limit protections, and to ignore legislated timelines for policies and reporting. Pressure can be applied to politicians by those with a vested interest in developing habitats of species at risk, or harming SARs. The process of protecting them must remain with scientists, and remain outside of the political arena,

I am further concerned that multiple delays are proposed for the listing, planning and reporting on species at risk, undermining species recovery. Of deep concern to me is the proposal to list species nine months after COSSARO makes its assessments public, because during this time vulnerable plants, animals and their habitats could be eliminated before protections kick in.

I am completely opposed to the “pay-to-slay” scheme that would enable habitat and species destruction by allowing developers and other proponents of harmful activities to pay into a fund in lieu of fulfilling requirements for on-the-ground reparation for the damage they do to species and their habitats.

Improving outcomes for Species at Risk requires enforcement, not weakening, of the law. It also requires investment in stewardship. I hope the Ontario government will step up to the plate to provide it, by better funding the Ministry of the Environment and the Ministry of Natural Resources and Forests. I urge the Ontario Government to reconsider all the issues I have raised about Bill 108.