I am dismayed this review…

I am dismayed this review and suggested amendments focus on changes to the ESA that are:

1. intended to promote industrial and development activities that will further harm the habitats of species already found to be at risk and result in increases to that list
2. call for further delay of listing species at risk and further delay of implementing protections for them
3.suggest ministerial discretion is necessary when decisions should be based on scientific evidence,
4. suggest industry and developers can simply pay into a fund to allow them to harm the habitat of species at risk.

Rather, to be effective to protect species at risk, protect their habitat and add in the recovery of the many species at risk in Ontario, this act should be amended to :

1. Repeal the 2013 exemptions as those industries are the major contributors of activities that harm the habitat of endangered species in Ontario
2. Authorize enforcement officers to inspect exempted activities to ensure compliance
3. Require applicants for harmful activities to submit to the government and the public their mitigation plans and report annually on them.

Many of the suggested amendment to the act are not need as the flexibility exits in the act as it is and are implementation issues .These proposal will weaken this act and contribute to further decline and extinction of species at risk. The people of Ontario love and respect nature and its diversity and expect our government to protect species at risk and not enact laws and regulations that contribute to their extinction.
The approach to assessment, listing and protection needs to be species specific to be effective and not changed to a landscape approach. Where this is appropriate already exists in the act.Species at risk cannot survive broad scale harmful activities, which should be obvious.This act must continue the process of scientific based listing and automatic protection of listed species and they habitat, not only where they currently exist but also where they could or have existed if that area was protected. There cannot be a continual decrease of habitat and this happens every time an exemption occurs to enable an activity harmful to their habitat.
The current act allows enough ministerial review if credible scientific information suggests an inappropriate listing. To increase ministerial discretion politicizes this endeavour and reduces transparency and delays protection of species at risk.
Permit process and exemptions already exits in the law for the limited circumstances they may be necessary. Remember this law is about protecting and the recovery species at risk, not about promoting activities harmful to the habitat! Habitat destruction and degradation is the greatest contributing factor to putting species at risk. There should be no change to the listing and automatic protections nor to the role of COSSARO whose approach is transparent.
Better communication can improve notice provisions.There is no need to lengthen the time for government to produce ERS, these are implementation issues, not a need to change the legislation.
The 5 year reporting is appropriate and reasonable to provide for transparency, ensure action, and need for adjustments in action etc.. Reporting should be every 5 years.
There is no need to change habitant regulation as the ministry can delay development of habitat regs.
There is enough flexibility in the ESA. The suggestions options are clearly intended to make it easer for industry and developers to undertake harmful activities which is not the purpose or intent of this act.There is no need to change the authorization process.
The proposal to pay into a conservation fund to enable proponents to proceed with harmful activities is
an affront to this legislation, the people of Ontario and certainly to the species at risk who should be protected.
Do not simplify the section 17(2)d permits exceptions.
Do not simplify exemption requirements through regs. Section 57 should be more stringent so exemptions provide a benefit to species at risk and not jeopardize their protection and recovery..
Section 18 does not need to be changed.
Rather, repeal the broad 2013 exemptions for forestry, hydro,mining, aggregate extraction etc., as their activities harm the habitat. Over 1800 exemptions in the 5 years since 2013 have violated ESA protections.
To protect the current species at risk and their habitat and to reduce the listing of more species and to have any hope for their recovery industrial activity has to be limited. The fallacy of a "balanced" approach allows more destructive activity further reducing the habitant species need to survive and thrive . We cannot allow this to continue to happen on our watch. We and future generations deserve the diversity of nature we are meant to have.