Comment
The ESA, in its current state, does not require any changes; these proposed changes, however, weaken the protections provided by the Act. For example, the current Act already considers landscape planning, so there is no need to replace the current species-specific approaches. Also, when dealing with species with declining populations, we must consider the individual effects of management actions. Species, particularly those that are at risk, can have very different habitat needs, and they often vary in their responses to human-induced landscape changes. Thus, shifting to landscape approaches, over ones that are species specific, can result in changes in land management practices that leave numerous at-risk populations even more vulnerable.
Yet another way that the propose changes weakens the act is that it allows the Ministry to apply discretion for automatic listings. Listing species is science-based, which ensures that the scientific rigor used to list all species are near equivalent. By allowing "discretion", which is seldom every based in science, can allow this process to become politicized.
Another concern is the change to allow GRSs beyond the 9-month deadline. This failure to meet deadlines is not because the Act is too stringent, it is because of poor implementation.
Generally, poor implementation is what plagues the ESA. One example of this is the suggested change to make it easier for industry to proceed with harmful activities. There’s already an authorization process that can allow industry to proceed with activities, if there is a net benefit to the protected species. Since the act already allows for companies to commence activities when species may be harmed, any issues with current authorizations (e.g., speed, scope) is not a failing it the Act. It is likely because of poor implementation (not enough human resources, for instance).
Submitted February 28, 2019 4:44 PM
Comment on
10th Year Review of Ontario’s Endangered Species Act: Discussion Paper
ERO number
013-4143
Comment ID
22740
Commenting on behalf of
Comment status