I am submitting this comment…

I am submitting this comment both as a concerned citizen, as well as an Arborist, Butternut Health Expert and Landscape Architect working in the environmental field.

Re. ERO 019-8016 Regulatory changes under the Endangered Species Act

I urge you to revise the proposed amendments to regulations under the Endangered Species Act, 2007 (ESA). The proposed changes will undercut critical rules to protect many of Ontario’s most vulnerable plants and animals. All the proposed amendments are intended to speed up or reduce restrictions on activities that harm those species.

This action seems counterintuitive when you consider that more species are being added to the Species at Risk list than are being downgraded due to recovery efforts.

The proposal to redefine habitat regulation for Redside Dace in O. Reg 832/21, would reduce restrictions on harmful activities targeting non-occupied habitat and undermine species recovery efforts.

The proposal to amend O. Reg. 830/21 to remove the 30-day waiting period between submission of a Butternut Health Expert Report and activity exemption registration undermines the legitimacy of the program and eliminates accountability.

I would instead propose that the 30-day waiting period remain in place, but that the Notice of Impact to Butternut Assessment be submitted at the same time as the Butternut Assessment report, to be reviewed concurrently, limiting the total waiting period to 30 days.

As it stands, applicants must wait for 30 days for the butternut report to be reviewed before submitting a Notice of Impact Assessment. This would significantly reduce the delay without compromising the integrity of the policy.

The proposal to amend O. Reg. 242/08 to allow the application of the exemptions in the regulation for select newly listed species would disregard the concern and urgency to act on behalf of the newly listed species.

Species at risk in Ontario are at a tipping point and the province is “losing more biodiversity than we are conserving,” according to the Ontario Biodiversity Council.

I understand one of the reasons that these amendments are being proposed is to streamline development application approvals. I would ask that instead the province focus on ways greenfield development can be reduced (which has a greater effect on SAR habitats), and instead ask how they could streamline infill development, perhaps through funding updated urban infrastructure and urban planning studies and processes targeting urban growth that is sustainable and creates healthy communities for both Ontario residents and the natural environment.

Your ministry should not proceed with the proposed regulatory amendments, but should focus on upholding provincial, national, and global commitments to halt and reverse biodiversity loss by 2030.
Thank you for your consideration.