To whom it may concern,…

To whom it may concern,

Thank you for providing the opportunity to comment on this proposal. As a professional that has been involved in the Endangered Species Act (ESA), including field data collection, as well as drafting and executing permits process for over a decade, I agree that the process requires improvement. However, it has been my experience that delays are mainly the result of proponents who decline to conduct sufficent data collection, or consultants that conduct inadequate surveys, resulting in a lack of data to inform permitting decisions, which inherently makes the permitting more cumbersome. Additional issues include a very small number of dedicated MECP staff to serve a massive volume of permit submissions, and the fact that many at-risk species still suffer from a lack of data on some of their basic life history requirements. Any piece of legislation/process would function poorly if it was supported in the way the ESA is.

In my lifetime a number of species and sub-populations of species have become extirpated in Ontario, some during the time in which the ESA was in effect. The current proposal will only weaken protections and lead to many additional species being eliminated from the province. I recognize this may be the goal, and I disagree with this as well. Additionally, most recovery strategies acknowledge that habitat loss from development is one of they key contributing factors to species loss in this province, and yet the proposal specifically aims to give development more favour when it conflicts with species at risk.

I oppose the ability of the government to have discretion to remove species from the list of protected species, as it is a conflict of interested. Science should be the driver of species listing.

I oppose the proposed changes to the definition of habitat. Many species at risk have large home ranges and depend on various micro-habitats within this area for critical life processes or require larger areas of habitat beyond the individual for successful reproduction. Connected habitat is critical to the preservation and recovery of many listed species. The proposed habitat changes will ignore these requirements. It should be noted that there are already various currently listed habitat categories/areas that can generally be developed/impacted without a permit or registration.

I oppose the removal of provincial protections to species also protected by the federal Species at Risk Act (SARA). In review of the SARA, it appears that the federal government would need to make an order that the SARA restrictions apply to provincial lands. I am not sure the federal government is up to the task of the onslaught of Bobolink and Eastern Meadowlark permits this change would generate.

I oppose the removal of the requirement for the province to draft recovery strategies. Removing the requirement for a recovery strategy will only increase the lack of information for listed species, making it difficult to mitigate impacts or promote positive actions, as in a void of information, it will be challenging to know what appropriate actions might be. Additionally, the provincial government already references federal recovery strategies for various species that only exist in Ontario (for example, Dwarf Hackberry), so it is unclear the duplication that the proposal is referring to.

I support increases in conservation initiatives, such as the Species Conservation Action Agency, but anecdotally provincial-funding for Species at Risk research has been declining in recent years, so would the increase just be back to prior levels? It would be difficult to think that this government would be able to fund such an organization to the point it would make up for the individuals and habitats to be lost in the wake of the other proposed changes.

No comments on the Species Conservation Action Agency. Though controversial I was interested to see if this organization could be a net positive for listed species.

I support any and all increases to compliance and enforcement actions to protect at-risk species and their habitats.

I oppose the registration-first approach. Registrations as utilized today provide the most limited in species protections (mitigation only in most cases) and do not provide replacement habitat, except in so-far as the Conservation Fund could have, and even then it is not a good fit for many species. For plants that are at-risk because of disease or pests, registration and replanting or other positive measure seems reasonable. However, one would be challenged to ‘replant’ some Eastern Foxsnakes in a new location and have the same overall effect, especially when the cause of the decline is overwhelmingly a reduction of habitat. Additionally, if 95% of the projects subject to the current ESA are currently registered, that implies that the proposed changes to the legislation are driven by the remaining 5% of projects? It seems unbalanced that such a small percentage of projects would drive such a massive change in legislation.

If the province genuinely wanted to improve the execution of the ESA, there is a highly-specialized army of dedicated people that would happily assist in working to improve the process, including myself, and I have in fact volunteered my time with the government in this capacity. I do not feel this proposal will improve the ESA or the plight of at-risk species in the province and am generally opposed to this proposal. I hope the government reconsiders these changes and reaches out to those in the field to revise the ESA in a manner that does provide more certainty to proponents while not sacrificing the well-being of at-risk species in this province.