Re: ERO # 019-8016,…

Re: ERO # 019-8016, Regulatory changes under the Endangered Species Act

The Algonquin to Adirondacks (A2A) Collaborative is a Canadian, U.S. and First Nations organization of over 50 partners that works with scientists, policy-makers and a variety of conservation groups to protect and enhance the unique ecological features and functions of the region stretching from and encompassing Algonquin Park in Ontario and Adirondack Park in New York State.

It is vital to the long-term health of Ontario’s natural environment, wildlife and wildlife habitat that the provisions of the Endangered Species Act (ESA) are maintained and extended, and that regulations are fully enforced. Therefore, we strongly oppose the regulatory change proposals of ERO # 019-8016, which are the latest attempt by the Ontario government to further downgrade protection of endangered species and their habitat in the province.

Specifically, we oppose:

- Proposed changes to the regulations defining the habitat of the endangered Redside Dace. This species is only found in few locations in Canada, all near and north of Toronto. The proposed regulatory changes appear designed to limit the use of the ESA in protecting Redside Dace habitat along the route of the proposed 413 highway. It is critical for the survival of this species in Canada that this habitat be protected.

- Removal of the thirty-day waiting period between the submission of a Butternut Health Expert Report and the registration and commencement of activities that may harm the species. This waiting period is important to give authorities time to evaluate the findings of the Expert Report.

- Addition of newly-listed species to existing ESA exemptions These exemptions are harmful to species at risk and should not be automatically extended to newly-listed species.

- Addition of early mining exploration trails construction, re-opening and use to the existing exemptions from ESA regulations for mining exploration. There is already a lack of enforcement of mining regulations. Further exemptions must not be allowed.

We ask that all of these proposed changes be rejected, and that the government refrain from proposing any other legislation or regulatory changes that will harm species at risk or their habitat. Furthermore, we ask that existing ESA regulations be fully enforced.

Sincerely,

The Executive
Algonquin to Adirondacks Collaborative