I am writing to oppose many…

I am writing to oppose many changes to the Endangered Species Act proposed in the 10th Year Review by the Ministry of Environment, Conservation & Parks. As an environmental science university student and a concerned citizen of Ontario, I am utterly disappointed by the proposed changes by the Ontario government to potentially bring devastating effects to the protected species of Ontario. Below I have listed my concerns regarding the specific changes:

1. the MECP wants to implement the so-called "Canada’s first independent Crown agency proposed to be called the Species at Risk Conservation Trust" that allow developers & other
proponents of harmful activities to pay into a fund rather than fulfilling requirements for on-the-ground
compensation. This completely disregards the accountability developers and other proponents are currently held under and makes it extremely easy to simply "Pay to Slay". This attitude of allowing money to be exchanged for precious habitat and allowance of irreversible changes leading to habitat loss is dangerous and irresponsible. Quite frankly, an economic value should not be placed on endangered species and the greed to build should not have a way around the law.

2. The broadening of the COSSARO membership to include individuals with "community knowledge". COSSARO is currently composed of qualified scientists who conduct science-based assessments of whether a species is at risk. By allowing the broadening of membership and community members to join the committee, this accountability and qualification is taken away from the COSSARO. You simply cannot provide a sound judgement on the status of a species without the proper scientific background pertaining to ecology, environmental science, ecological restoration, and wildlife management. This vague term will permit many loopholes for unrestricted personnel to join the COSSARO, what is the point of the committee if anyone can join? As the government of Ontario, it is your responsibility to ensure the natural resources and habitat of Ontario native flora and fauna are protected and that comes with holding your personnel accountable and ensuring their qualifications.

3. Ministerial veto of automatic protections. Within the proposed changes in section 2 Defining and implementing species and habitat protections, this line is particularly concerning: "the proposed changes would provide the Minister with authority to temporarily suspend species and habitat protections for up to three years". This is also mentioned to be exempt from the Environmental Bill of Rights posting and regulation requirements if proposed legislative changes are passed. The public will have no notice or input on said decisions and delays, with 3 years being the timeline my concern lies in the complete destruction of habitat and eventual extinction of species at risk during this 3 year period of absolute non-transparency. With a suspension of species and habitat protection of up to 3 years, what is the point of even having a regulation at all? There is no reasonable conclusion as to why this is acceptable other than the fact that social and economic considerations are again placed before the wellbeing of species at risk. This to me is the government's statement of " we do not care" and as a young environmental professional it disappoints me greatly to see that the political leaders of my province has this kind of non proactive attitude in place. Species at risk are also proposed to be "de-coupled" from automatic protections for threatened & endangered species & their habitats and the Minister would have greater “discretion on protections.” This can be unimaginably devastating to species at risk. Despite your statement that "the temporary suspension will not jeopardize the survival of the species in Ontario", I find it hard to believe that you would be able to ensure no jeopardizing occurs with the broad timeline of 3 years. What are the proposed plans? How will you ensure there is no jeopardizing? If you are saying that you will suspend the protection for 3 years are you implementing monitoring plans so that the species population doesn't decline at all during this period? You are not holding yourselves accountable in anyway through this statement. Coming from an ecology background, I understand the effects of ecological cascade and the catastrophe it brings. By suspending the protection of one species, there are chain reactions that will fuel into an ecosystem issue beyond the scope of a single species at risk. What we are facing will be the ecological degradation of the entire province.

I sincerely hope you will consider my comments on the proposed changes. I come from a place of disappointment yet I remain hopeful that the Ontario government will see the urgent needs and requests from concerned citizens around the province. The proposed changes to the endangered species act is not only dangerous to the species at risk but also opens up doors for corporate greed and sets the framework for further prioritization of the economy before our native flora and fauna. We rely on the environment and co-exist with the species around us. With the authority you have over how you regulate citizens and companies, it should be an intrinsic responsibility to consider the wellbeing of species at risk (and quite frankly the environment overall) before you propose any changes to the ESA.