Dear Honourable Rod Phillips, Minister of the Environment, Conservation and Parks

Cc: Environmental Registry of Ontario (ERO)

Cc: Todd Smith MPP, Bay of Quinte


Re: ERO 013-5033 : 10th Year Review of Ontario's Endangered Species Act

Dear Mr. Phillips,

I read your comments regarding your plan to cooperate with developers by neutering the Ontario Endangered Species Act in the account in the Globe and Mail April 18. They could be described merely as risible and fatuous if they were not so alarming, coming as they do from the officer of the government charged with protecting environmental interests.

You should consider renaming your department the Ministry of Industrial Development. Ontario has occasionally had good Ministers of Environment in place since that department was created in the late 1960's, but you clearly are not one of them.

For you to say "This payment is not an opportunity for business to walk away, it is an opportunity for an increased efficiency and a more strategic focus on how we preserve species in their habitat" is an appalling remark for a responsible official to make. What Orwellian rubbish. You reveal either simple ignorance or a willful intent to deceive the Ontario people.

I have been employed by the MoE in years past and I know of what I speak.

However I suppose one should not be surprised given the attitude of your government towards the accelerating threat of climate change, and your helpful plan to place government stickers on gasoline pumps encouraging us to ignore the whole issue.

The analysis of Mr. Schreiner, Mr. Gray and Mr. Arthur as given in the Globe article are spot on. You should listen to these people as they are competent.

Otherwise I suggest you resign and look for work for which you have some aptitude.

Yours

Alban Goddard Hill B Sc, MD
Eastern Lake Ontario Environmental Research Group
eloerg.tripod.com/waupoos2012

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Ontario plans to address developers' needs in new Endangered Species Act

The Globe and Mail Newspaper
Stephen Cook
Published April 18, 2019
Tijana Martin/The Canadian Press


Ontario says proposed changes to endangered-species regulations will protect species and balance the needs of developers in what critics say is a blow to environmental protection.

On Thursday, Environment Minister Rod Phillips presented major proposed changes to the Endangered Species Act, which gives legal protections to threatened and endangered species as classified by an independent committee.

Alterations to the act include additional ministerial oversight and a new pay-in-lieu option rather than damage mitigation.

Developers would have the choice to pay a regulatory charge instead of completing on-the-ground activities required by the act to mitigate damage caused through development, such as planting trees of the same species elsewhere. Mr. Phillips said the cost would be close to those required for mitigation but that there would be further consultation.

The money would go into a Crown agency called the Species at Risk Conservation Trust, which will then disburse the funds to third parties to support protection and recovery.

"This payment is not an opportunity for business to walk away," Mr. Phillips said. "It is an opportunity for an increased efficiency and a more strategic focus on how we preserve species in their habitat."

The minister would also have the ability to establish guidelines for how the funding is used.

Initial response to the pay-in-lieu model was highly critical, with Green Party leader Mike Schreiner calling it a "pay-to-kill provision."

"Essentially you are saying to developers, "Yeah go ahead and cut the tree down, but if you pay into a fund we will do a bit of research," he said to reporters after the presentation. "Well you know what? It is pretty hard to do research when the butternut trees are already cut down."

Mr. Phillips used the butternut tree as an example of a species primarily threatened by disease where money from the trust fund could be used to research treatment.

He said the proposed changes were made in response to the findings of a 45-day public consultation launched in January.

"We have heard how the processes to obtain permits can be long, frustrating and unpredictable and how they can shift the focus away from finding the best solutions to protect species" he said, adding that changes were designed to streamline processes and create more "realistic" timelines.

The proposal increases the time frame of listing newly classified species to 12 months from three, including species classified in 2019. It also gives the minister the authority to suspend protections under certain criteria for up to three years, whereas those protections are currently automatic when a species is added to the list.

The Committee on the Status of Species at Risk in Ontario (COSSARO), which manages the list, must also take additional direction from the minister as well as consider a species' wider geographic area, both inside and outside Ontario, meaning those creatures not at risk in other areas would be candidates for delisting.

Membership of that committee would also be broadened solely from scientists and persons with Aboriginal traditional knowledge to include those with relevant expertise in ecology, wildlife management and community knowledge.

"So now you are going to be able to put people on there who may not even believe that endangered species are important", said Tim Gray, executive director of the Environmental Defence advocacy group, who called the changes "shocking and indefensible".


"I think it is clearly an attack on some of the environmental protections that we have had," NDP environmental critic Ian Arthur said. "This is Premier Ford opening another avenue to conduct backroom deals with his developer buddies in Ontario."

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Eastern Lake Ontario Environmental Research Group