Ontario Road Builders'…

Ontario Road Builders' Association (ORBA) Submission to ERO Posting 013-4143: 10th Year Review of Ontario’s Endangered Species Act: Discussion Paper.

March 4, 2019

Submitted online through the ERO website at: https://ero.ontario.ca/notice/013-4143

Public Input Coordinator
Species Conservation Policy Branch
300 Water Street
Floor 5N
Peterborough ON K9J 3C7
Canada

On behalf of our members, The Ontario Road Builders’ Association (ORBA) appreciates the opportunity to provide a written submission in response to the ERO posting 013-4143: 10th Year Review of Ontario’s Endangered Species Act: Discussion Paper.

The Ontario Road Builders’ Association is the voice of the road building sector in Ontario. Our members build the majority of provincial and municipal roads, bridges and transportation infrastructure across the province. The road building sector directly employs in excess of 30,000 workers at peak season and impacts all Ontarians.

ORBA is committed to the principles of sustainability and environmental stewardship. We strive to promote best practices in environmental stewardship and project management among our member companies and the goals of reduced consumption of virgin resources, reduced impacts on the environment and reduced waste. In keeping with these principles, we support the government’s commitment to ensuring that the Endangered Species Act (ESA) “provides stringent protections for species at risk, while continuing to work with stakeholders to improve the effectiveness of the program.”

We welcome the review and the consultation approach towards seeking opportunities to improve processes. Our members support an ESA process that is guided by the measures of responsible, reasonable, timely, evidenced based requirements, with clear protocols, adequate lead time for implementation, and efficient processes for review and decision making.

Transportation infrastructure projects in Ontario must be delivered in short time frames due to seasonal factors. Projects therefore require dependable work schedules that optimize all opportunities to complete the work in a timely manner. Delays due to uncertainty or lengthy, linear multi-party review functions are costly without necessarily adding environmental protection benefits. Ministry guidelines and timelines should provide for a dependable and transparent review process for ESA approvals.

We note that species are automatically listed based on Committee on the Status of Species at Risk in Ontario (COSSARO) recommendations. Our members are of the view that identification of new species should be further reviewed and approved by the government. This approach would ensure transparent, evidence-based assessments with defined processes and timelines to resolve potential issues and presents an enhanced opportunity for government to fully consider the impact of new listing recommendations on transportation infrastructure projects.

We would like to thank you for the opportunity to comment, and we look forward to further discussion opportunities regarding this important review. Please do not hesitate to contact Andrew Hurd at 905-507-1107 ext. 223 if you have any questions or concerns.