May
7, 2013
The
Honourable Kathleen Wynne
Premier
of Ontario
Legislative
Building
Queens
Park
Toronto,
Ontario
M7A
1A1
Dear
Premier Wynne,
Re:
Proposed exemptions under the Endangered Species Act, 2007
It
is our understanding that the Ministry of Natural Resources (MNR) is proceeding
with its plans to create a broad new suite of exemptions under the Endangered Species Act, 2007 (ESA), and
that Cabinet will be making a final decision about this proposal in the very
near future. We are writing to urge your government to turn down this
ill-advised proposal.
On
March 1st of this year, 54 environmental organizations co-signed a
letter to you outlining our concerns about the exemptions and requesting that
they be withdrawn. Thousands upon thousands of Ontarians have expressed their
disapproval of the exemptions. Collectively, we have tried through various
means (participation in public consultations, letters to relevant Ministers,
meetings with staff at your office and the office of Minister Orazietti) both
to convey our opposition to the proposal and to offer alternatives. But to no
avail.
We
are left wondering how it could be that your government which so proudly passed
the ESA only a few years ago could now be turning its back on endangered
species and on those of us who hailed this new law as the gold standard in
Canada and beyond. There seem to be two possible explanations: either the
government has indeed made a conscious decision to change direction and no
longer stands behind the legislated purpose and intent of the ESA, or it has
been misinformed by the MNR about the intent and likely impacts of the proposed
exemptions. Certainly the MNR has been less than fully transparent with the
public about the real implications of and reasons for these proposed changes.
Premier,
we are deeply appreciative of the many significant steps that have been taken
by the Liberal government to improve environmental law and policy in Ontario.
The reintroduction of the Local Food Act and the Great Lakes Protection Act is
a strong signal of your ongoing commitment to fostering healthy, sustainable
communities. Yet we have to ask whether your government will stand behind its
own legislation in the years to come. The proposed exemptions to the ESA cast a
disturbing shadow of doubt across your green agenda and legacy.
There
is no doubt that the proposed exemptions would severely weaken the ESA’s current
standard of protection and undermine the government’s ability to monitor and
control activities that harm threatened and endangered species and their
habitats. Indeed, some organizations have raised concerns that the Ministry's
proposed regulatory approach is contrary to law.
While
we acknowledge that there have been many challenges in implementing the ESA, broad
exemptions are not the appropriate way to address them. There are other viable
options which should be explored. These include fair and fiscally responsible
ways to address the deficit. We are willing to discuss these opportunities at
any time.
Thank
you for your attention to this urgent matter. We look forward to your response.
Yours
truly,
David
Goodyear
President
Muskoka
Field Naturalists
cc.
The Honourable David Orazietti,
Minister of Natural Resources
The Honourable Charles Sousa, Minister of
Finance
Gordon Miller, Environmental
Commissioner of Ontario