Response to ERO-019-8016…

Response to ERO-019-8016 Regulatory changes under the Endangered Species Act to improve implementation of the species at risk program

Proposal 1: Regulatory amendments regarding habitat protections for Redside Dace

I recommend that the protections for Redside Dace be PRESERVED AS WRiTTEN, that NO REDUCTIONS OF CURRENT PROTECTED AREAS be made, and that all streams so protected be inspected for condition. Putting it another way, I urge those in charge to retain the current definition of recovery habitat for the Redside Dace in order to make it possible for this species to make a recovery. If the condition of the stream is such that re-introduced Redside Dace would not survive, then I recommend that the stream be restored to a condition where the Redside Dace would survive. Lack of survival of the Redside Dace in streams where it used to thrive is one more indication that we are degrading the very environment that sustains us.

Proposal 2: Regulatory amendments regarding select conservation fund species and related administrative changes

These amendments only make it easier for development proponents to destroy habitat for species at risk. Paying into a general fund whose eventual distribution is uncertain is no substitute for protection of current habitat. The Butternut is one example of a species that needs all the protection it can get. There may be pockets of healthy butternut that are the key to the survival of the species. So when butternut are found still living under any condition, they should be fully protected until people who understand the requirements of butternut for survival have had a significant amount of time to study their condition and consider their future ability to survive and reproduce. We do not need to develop any more new land for housing. We need to build housing in existing communities with existing infrastructure so that we can build affordable housing where people want to live. Destroying habitat for species at risk is just another route to self-destruction of the human species. That is what the Endangered Species Act was meant to do…protect the natural world so it can sustain humanity into the future.

Proposal 3: Regulatory amendments to add newly listed species to existing exemptions and other administrative changes

Rather than “maintaining standards for protecting species at risk”, this proposal will speed up activities harmful to species at risk. The Auditor General has reviewed the results of the species already exempted, and calculated that the approvals under this exemption have increased the incidents of harm to species at risk by more than 60 times between 2008 and 2020. This is a record to be ashamed of. How will you explain to your grandchildren that you were complicit in such a process? We have the knowledge and the capability. Why not use it to make life better for our children and theirs, not worse!

Proposal 4. Regulatory amendments regarding the conditional exemption for early exploration mining
Potential amendments to include early exploration mining trails as an eligible activity

Mining activity has been allowed to go ahead with very little oversight with regard to species at risk and these new amendments will only make the situation worse for the natural environment that sustains us. If this government truly meant to protect species at risk, they would be funding the ministry so that qualified inspectors could be out there working with the mining companies to truly protect species at risk. These species and their habitat is what is going to help mitigate our deleterious effects on the climate, and if we keep destroying it, we are destroying our own habitat. Imagine that every species at risk whose habitat you destroy is the equivalent of your grandchild’s home. Then you will understand how important real protection is.