Thank you for the…

Thank you for the opportunity to add our voices to the public consultation on the discussion paper as part of the review of the Endangered Species Act. I wish to indicate at the outset that none of our family has a competing interest, as no one works for a conservation agency or a provincial of federal park. We are, however, deeply concerned about maintaining the environmental integrity and vitality of our province!

Although the Discussion Paper outlined four major focus areas, our family's response will address only two directly -- #1 Landscape Approaches and #3 Species Recovery. Overall, from what we read and see personally, what is needed is actually greater protections to help recover the province’s at-risk species. The studies in this area seem clear that resource extraction, habitat loss, and industrial activities continue to threaten the survival and recovery of wildlife throughout Ontario. We live on the Bruce Peninsula and we see this happening all around us as precious habitat is destroyed for "development" (forestry, quarries, housing). Although there are important and unique natural areas around us, the approach so often taken is one of act first and ask forgiveness later! This results in the loss or irreparable damage to ecosystems that cannot "forgiven" or replaced. Other members of our family live in the Golden Horseshoe, and they witness similar threats there.
Indeed, the "report card" for Ontario seems to indicate that we are not achieving many of our goals in species protection. If our personal experiences are at all representative, it is small wonder. Ecosystems and habitats are NOT being protected and preserved. Rather, they are being destroyed and fragmented.

#1 Landscape approaches
While I am not entirely clear about this term and its implications, there is very reasonable evidence that habitat protection is vital to species viability, resilience and recovery. Thus, we urge you to focus MORE attention on habitat-protection measures -- approaches that are effective for the listed species and that address the increasing threats from invasive species. Properly addressed, this will simultaneously improve outcomes for multiple species -- those at risk and those that may become endangered by our inaction.
• Support local communities in developing activities and policies that maintain and restore endangered species and their habitat, including rural and northern communities.
• Work with organizations such as Nature Conservancy Canada, Bruce Trail Conservancy, Escarpment Biosphere Conservancy. Biosphere Associations, etc to promote their crucial work in this area. Nature Conservancy in collaboration with universities has been developing tools that could provide leadership in this area. Their focus has shifted to preserving those landscapes that are most likely to endure and maintain as wide a variety of characteristics to preserve as many species as possible (see links below). This could have broad benefits for everyone, as well as for species at risk!
• Support the continued leadership and critical role of Indigenous Peoples in conservation initiatives.
• Work with other ministries (provincial AND federal) to ensure coordination to limit cumulative impacts on the lands and waters that provide wildlife habitat.

#3 Species Recovery Policies and Habitat Regulations
As mentioned above, there definitely is potential benefit to harmonizing approaches to habitat protections more broadly. Indeed, we would support a shift towards an ecosystem-based approach that conserves large expanses of habitat and addresses the needs of several species at once, rather than trying to protect individual species.
However, we do have major concerns about two of the bulleted “permits” under the Act (p 6 of Discussion Paper) that could allow exemptions -- (1) Significant social or economic benefit permit, s. 17(2)(d): A significant social or economic benefit permit may be issued for an activity that will result in a significant social or economic benefit to Ontario, but the activity would have impacts that are otherwise prohibited under the Act. and (2) Regulatory exemption, s. 55: An exemption may be made in a regulation that allows activities to impact species at risk without requiring a permit, provided the requirements of the regulation are met. These exemptions are very broad and have the potential to be abused with too little thought given to the environmental impacts (as already is occurring too frequently now).
We suggest --
• Amend the Act to actually set a higher bar for species at risk -- by ensuring exemptions cannot jeopardize the recovery of threatened or endangered species.
• Do not extend timelines (p 5 of Discussion Paper) without clear and public explanation of the rationale. In particular, a review of progress towards the protection and recovery of a species within five years of the Government Response Statement would rarely be too soon to see if there is any impact at all. Waiting longer is quite likely to mean waiting until it is too late!

Thank you for considering our perspectives.