Comment
I do not support the current 'open for business' approach we are seeing in Ontario environmental policy, particularly in the ESA. Deregulation to make it easier for industry and development, at the expense of irreplaceable habitat and species, it not something I support for Ontario's future.
The ESA, as it currently is, needs to be more strongly implemented - the MNRF should more often deny permits for activities that harm or harass endangered/threatened species or threaten their habitat. Too often a lack of implementation makes our laws weak, and in the face of climate change and accelerated habitat destruction we can not ignore the synergistic effects this has on our natural world. The law should not be changed to authorize harmful activities at a broad scale, as this doesn't allow for site- or species-specific assessments and leads to unnecessary additional risks for species that are already endangered.
Further, there should not be a change to science-based listings and automatic protections. There should be no change to the ESA regarding the listing based on a consideration of the best available scientific information. There should not be an alternative to automatic species and habitat protection, especially not through ministerial discretion to remove or delay protections.
Species listed as endangered are already in considerable peril and require immediate action to reverse their decline. There should be no change to the legal requirement to produce Government Response Strategies within nine months of the Recovery Strategies, or the five-year reporting requirement. There should not be a change to the legal provisions for habitat regulations. Protecting areas where the species has previously or is capable of living strengthens our capability of recovering populations of endangered species, and should be strongly enforced.
Intact ecosystems provides thousands of free benefits (i.e. pollution regulation, food, tourism, nutrient cycling) that already provide a benefit to business, industry, and society at large. Species are an integral part to ecosystems and they should be protected. The priority of this act should be on protecting and recovering species at risk. There is no room to make it easier for development or industry to circumvent regulations, or conduct harmful activities. There is ample evidence that paying into a fund in exchange for conducting harmful activities does not lead to species recovery or habitat protection. Protecting species and preventing habitat loss should be the main priority of this act.
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Submitted February 28, 2019 7:24 PM
Comment on
10th Year Review of Ontario’s Endangered Species Act: Discussion Paper
ERO number
013-4143
Comment ID
22803
Commenting on behalf of
Comment status