ESA comments: 1. Purpose…

ESA comments:
1. Purpose
Comments:
- I disagree with the fundamental change to the purpose of the species protection legislation that it must take into account social and economic considerations. A strong and functional environment is integral to supporting the health and well-being of Ontarians. Having the purpose of this foundational legislation to expressly note economic considerations, without any mention of scientific support of this approach, is threatening to the future of our province. I do not support this language in the revised legislation.

2. Habitat
Comments:
- Plants and wildlife rely on a much greater area of habitat than their nesting/dwelling place and their critical root zone for growth, feeding, and reproduction. Failing to protect the vegetation communities that are critical to all life stages of these species is a major change to the ESA and is not supported by science as a way to protect the long-term survival and recovery of Species at Risk. I recommend retaining the existing habitat definitions.

3. Reduced Duplication with Federal Legislation:
Comments:
- Duplication between provincial and federal protections do exist, however removing protections for SARA protected aquatic species and migratory birds is short-sighted as the factors influencing a species’ threats may be different at the provincial and federal levels. I recommend a streamlined approach to permitting rather than complete removal of provincial protection of these species.

4. Recovery Plans and Documents:
Comments:
- As an ecological restoration practitioner I often us the science-based information in Recovery plans and documents to guide my work. In removing the requirement to develop recovery documents at a provincial level my restoration toolkit will be greatly diminished, as not all provincially designated species are also designated federally. I recommend continuing to create provincial recovery plans and documents, with the suggestion that where federal documents exist the provincial documents could be reduced or considered a supplement to the federal information.

5. Updated compliance and enforcement
Comments
- I support increased funding and power to enforce environmental regulations. In particular I would like to see specific steps outlined and funding committed by the government to support enforcement.