The proposed changes to…

The proposed changes to Ontario's Endangered Species Act will gut the program and render it ineffectual in protecting Ontario's biodiversity. I cannot support the proposed changes as written. I believe that accepting these changes and putting them into practice would be a huge step backwards for Ontario, and would open the door for corruption.

One of my major concerns with the proposed changes is the amount of power the Minister will wield. These changes allow the Minister to veto recommendations from COSSARO. This is a gross misuse of power. The Minister should not be able to undermine a committee composed of independent experts based only on the Minister's opinion. Not only does this open the door for major corruption from outside sources, but this also isn't logical. Ministers do not have to come from a scientific background relevant to their position - our current Minister, Rod Phillips, has no scientific background or training in environmental policy, conservation, or restoration science, and his previous experience was as the former CEO of the Ontario Lottery and Gaming Corporation. Allowing someone without the background or understanding of species to veto the decisions of people who do have this specialized knowledge is, frankly, asinine. This increased authority for the Minister is a recurring theme in the proposal, exacerbating other problematic proposed changes.

Another major problem with the proposed changes are the added delays at almost every step of the process. Currently, COSSARO submits a report to the Minister, who must then list the species on the SARO list within 3 months. The proposed changes extend this time period to 12 months, a needless delay and one that can be very harmful to species that are struggling to survive. Further delays are combined with the extra power that would be allotted to the Minister, as the Minister can decide to delay the development of Government Response Statements and review of the protection and recovery progress. There is no reason for these delays, which only hinder progress. Furthermore, the Minister can decide to suspend species and habitat protections for up to three years for newly listed species. This means that even if the Minister doesn't veto the recommendation, they can wait 12 months to even list the species then delay protections for that species for another three years. That means that a species that is identified as endangered right now could wait 4 years before any measures are taken to protect it. By that time, it could be extinct, and Ontario would have lost an important piece of its biodiversity. None of these delays help species recoveries, nor are they based on scientific or environmentally sound reasoning.

Another major problem lies with issuing Endangered Species Act permits and agreements and developing regulatory exemptions. Allowing corporations, municipalities, or anyone else to pay a fee instead of following protections put in place by the ESA is one of the worst changes proposed. I don't support this change, or any "pay to slay" policy. Allowing money to decide the future of Ontario's biodiversity is a crime to those who don't have the money to fight back. The average Ontarian can't stop corporations or industry from coming into our province and doing as they please. One way that we are protected is by putting regulations like the ESA into place, so that rich people can't decide what happens to our province just because they have money. The proposed system takes these protections away from us. Once again, this problem is exacerbated by the overwhelming amount of power that the Minister will be given. Within the proposed changes, the Minister no longer needs to meet with with independent experts when considering applications for permits and exemptions. This once again means that someone with no background in the field can make decisions without truly understanding the potential ramifications of that decision. It once again opens the door to corruption.

Another objection I have to the proposed changes are the changes to the SARO listing protocols. These changes will result in fewer protections for edge-of-range species. Ontario is the northernmost extent of ranges for many species currently listed under SARO. Protecting species over their entire ranges is important to preserving the species as a whole.

Finally, there is vague language around COSSARO membership being open to those with "community knowledge". While this seems like an effort on the part of the policy writers to be inclusive of non-traditional streams of knowledge, it is poorly defined, leaving the door to membership open to anyone who claims that they have "community knowledge". This language needs to be tightened up to reflect that COSSARO members need to have deep, intimate knowledge of the systems rather than superficial.

In summary, I disagree with the proposed changes to the Ontario Endangered Species Act. The goals of the proposal are to "improve the effectiveness of the program for species at risk by ensuring Ontario’s best-in-class endangered and threatened species protections; include advice and species’ classifications from an independent scientific committee and modern approaches to enforcement and compliance; species and habitat protections; and recovery planning". I do not think that the proposed changes meet any of these goals. It gives the Minister unprecedented (and unnecessary) power, and allows them to ignore the advice of experts. It weakens species and habitat protections, and delays the process at almost every level. It allows people with money to make decisions contrary to the will of the people who live here. It opens the door to corruption and scandal.

I do not support these changes. I am disappointed in the proposal and charge Ontario with the creation of an ESA that actually protects our species rather than selling them out to the highest bidder. Protecting our biodiversity is of the utmost importance during the ongoing global biodiversity crisis. We need to start by protecting our species at home, and the first step to that is fixing this proposal.