Submission to the Ministry of the Environment Regarding Reflective Surfaces and Bird Mortality

The Halton/North Peel Naturalist Club is concerned with the Ministry of the Environment’s proposed amendment to exempt reflective surfaces of buildings from having to obtain an Environmental Compliance Approval.
Surely the Ministry of the Environment is well aware of the tremendous number of birds that die or suffer injury after colliding with windows. The toll is well documented. The Fatal Light Awareness Project estimates that 9 million birds die in Toronto alone after flying into buildings. Extrapolate that number across the province and the message is abundantly clear: window collisions are having a significant impact on bird populations. That some of the bird species are species at risk (bobolinks, chimney swifts, barn swallows for example) adds to the urgency of dealing with the problem.dead_bird
The Annual Report of the Environmental Commissioner of Ontario released on November 3, 2015 laments the proposed exemption stating ” … it appears that the ministry’s [Ministry of the Environment] preferred approach is to ignore its regulatory responsibility and leave it up to property owners and managers to voluntarily follow guidelines and suggested strategies. ”
Michael Mesure of Fatal Light Awareness Project sites the obvious flaw in this approach. He notes that in FLAP’s 22 years of work surrounding bird-building collisions he’s found that “corporate owners aren’t interested in voluntary action.”
This isn’t at all surprising. It’s simply not in the financial interest of corporations to voluntarily comply. If the government is truly interested in mitigating bird deaths associated with window collisions and in supporting avian diversity in Ontario it has to ensure that property owners be required to take appropriate steps to significantly reduce bird collisions.
If this isn’t done, bird mortality will only increase as our towns and cities continue to grow. Bird-building safety must be addressed by the government if we truly want a bio-diverse future.

Please do not allow this exemption to proceed.
Don Scallen
President Halton/North Peel Naturalist Club
On behalf of the Halton/North Peel Naturalist Club

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