After having reviewed the…

After having reviewed the proposed amendments, I am deeply concerned for the species at risk in Ontario. It appears that your provincial government is going against your own Endangered Species Act, and removing protections from species that are Endangered and have not recovered. I am particularly concerned about the changes to Redside Dace. It is clear that these changes are being put forward to benefit developers and put more money in the premiers' friend's pockets. It is appalling. Redside Dace will surely be extinct from the GTA in our lifetime if protections are not kept in place.

The proposed amendments do not protect Redside Dace or their habitats and are detrimental to the recovery of the species in Ontario. The proposed regulation change, which effectively reduces the extent and duration of protected habitat, is contrary to the goal of the Ontario Government Response Statement to the Redside Dace Recovery Strategy. Furthermore, the trend of the species continues to spiral toward extinction. Reducing species-specific habitat protections under the Endangered Species Act is not a prudent direction for the Government of Ontario at this time. The proposed amendments (i.e., reducing tenure from 20 to 10 years) will have a negative impact on 2 watersheds and 13 subwatersheds, thereby removing them as “occupied” habitat under section 29 of the habitat regulation. This would ultimately decrease habitat protections for the species under the Endangered Species Act from 14 watersheds consisting of 44 subwatersheds down to 12 watersheds consisting of 31 subwatersheds. By removing these watercourses as “occupied” habitat without a thorough assessment of occupancy, the proposed amendments reduce protection for the species across a number of watercourses and may ultimately jeopardize the survival of the species in Ontario.

Changes to the classification of “recovery” habitat also results in significant changes to watercourses identified as “recovery” habitat under section 29 of the habitat regulation. While it is recognized that some habitats previously occupied by Redside Dace have been lost and have already been removed as recovery habitat, the generalization of recovery habitat in the proposed changes has the potential to significantly reduce recovery habitat further.

Given the significant concerns regarding the proposed changes related to O. Reg 832/21 it is my informed opinion that the proposed changes as written will result in detrimental impacts to the species and ultimately jeopardize the recovery of Redside Dace in Ontario.