I am dismayed that it seems…

I am dismayed that it seems necessary to remind you, the government, of the original purpose of the ESA:
1. To identify species at risk based on the best available scientific information, including information obtained from community knowledge and aboriginal traditional knowledge.
2. To protect species that are at risk and their habitats, and to promote the recovery of species that are at risk.
3. To promote stewardship activities to assist in the protection and recovery of species that are at risk. 2007, c. 6, s. 1.

The discussion paper’s tone and wording, especially of the discussion questions, seems more like a thinly veiled way to guide the readers to think how best to help developers.
- For example, such as when the discussion paper states “There is not enough public notice before a new species is automatically listed on the Species at Risk in Ontario List.” Not enough notice? According to who? Wouldn’t being swiftly listed be a BENEFIT to a species, especially one that is dwindling, rather than slowing the process?
- As another example, when the discussion paper states “In some cases, the time limit of nine months to develop the Government Response Statement for an endangered or threatened species is too short, and there is no option under the Act to extend this timeline when needed”. Too short - really? According to who, exactly? If you (government) had the political will to put more staff on the GRS work, the GRS’s would get done on time. I say ‘political will’ rather than ‘funding’, because you’ve got the money, you just don’t want to spend it on species at risk. I’ve seen multiple events and areas and initiatives where the government wasted massive amounts of money; one need only check the ‘Teddy Awards’ at taxpayer.com for even a handful of examples.
- As another example, when the discussion paper states “The requirements that applicants must fulfill to obtain an authorization can be extensive, creating barriers to economic development (e.g., in some cases achieving an overall benefit to a species as required under a s. 17(2)(c) permit can be long, onerous, and unpredictable).” Well, this is less a thinly veiled intent than it is an open admission that businesses and developers see the preservation of biodiversity as a hindrance to their profits. However, Government, it is also your job to account for the Tragedy of the Commons. Our biodiversity is not a buzzword; we literally, factually, scientifically rely on a healthy system, a strongly bio-diverse system to provide us with nutrient-rich topsoil, free crop pollination, swimmable water, as well as beautiful spaces. In China, right now, there are areas where a lack of industry oversight and a lack of effective protective environmental legislation has completely removed the natural pollinators from the landscape such that they are now having to pollinate their crops by hand with little paintbrushes. The China press releases lie and say ‘it’s actually cheaper this way’, but they seem to think we don’t realize that nothing is cheaper than free. Let’s not go down the road they’ve gone, it leads to things literally disappearing off this planet, permanently. Extinction is the result of local extirpations carried out repeatedly across a landscape. Giving people license to go ahead and tear down/pave over an area here, and there, and elsewhere, without paying due attention to ways to avoid or mitigate damage, does just that.
- There are multiple natural places I used to visit when I was a teenager, and I remember seeing numerous species in droves in those places – Bobolink, Barn Swallow, Eastern Meadowlark, Chimney Swifts, Wood Thrush, Monarch Butterflies…when I visit those places now, those species are no longer there, (they're all listed species at risk now), and I’m not even 40 yet. The woodlots and forests and ponds near where I grew up no longer have Butternut, and now all the ash is gone too. That frightens me, and I’m deeply concerned that the people in charge of driving this boat don’t actually care about where it’s going…

Regarding “Should there be a different approach or alternative to automatic species and habitat protections? (e.g., longer transition periods or ministerial discretion on whether to apply, remove or temporarily delay protections for a threatened or endangered species, or its habitat”
- DON’T YOU DARE. I’m disgusted that this idea was even uttered. Ministerial discretion on whether to apply, remove, or delay protections? Are you hearing yourself? Say those words out loud and realize that there is really NO difference between a dictator and someone who is given complete discretion to override science to serve their own or industry’s interests. Political sway varies too much to leave that much power in one person’s hands. I am at a minimum deeply disturbed that the government would even entertain the notion of introducing ministerial discretion into decisions regarding habitat protection. Tell me Government, how would that NOT weaken the science-based listing process? At a minimum, it would allow politically motivated decisions to override evidence in favour of ideology. We are supposed to be a democracy.

If it wasn’t for the Environmental Commissioner saying the Liberals were ‘undermining the survival’ of species at risk, I’d think the Ontario government wasn’t interested in sustainable development.
Oh wait, the government dismissed the Environmental Commissioner…and didn’t replace him…I guess an unpopular statement, despite ample evidence supporting it, is an incorrect one worthy of dismissal?

Are you, the Ontario government, at all interested or invested in genuinely pursuing truly sustainable development? As someone who was employed by various “‘environmental’ consulting companies’” to ‘examine areas for environmental constraints’, I can assure you that leaving it up to developers to make the decisions that will affect the success of conservation efforts is NOT the way to go. I was paid to, and repeatedly explicitly instructed by multiple supervisors in various companies, to merely exploit the loopholes in protective environmental legislation and policy, rather than ensure either the spirit of it, or even the letter of it, is implemented.

I urge the Ontario government to recognize the self-evident logic of working within ecological limits, rather than pretending or hoping those limits do not exist. Pretending is lying to everyone, including yourself; and the hope that things will work out is not a plan to ensure it does. Which side of history do you want to be on – the side that bowed to political pressure, or the side that used defensible and credible scientific evidence to guide and support their decisions?

Even though I’m not a member of the Green Party, I support the recommendations as stated by its leader Mark Schreiner:
-Remove the 2013 exemptions for the forestry, hydro, aggregates, and mining industries that allow them to harm species at risk and destroy their habitat;
-Amend section 57 (1)1 of the ESA so that exemptions will only be allowed if they do not jeopardize the survival and recovery of endangered and threatened species;
-Restore an ‘overall benefit’ approach to species protection consistent with the 2007 Act before the Liberal government replaced this with a ‘minimize harm’ approach;
-Maintain the independent and expert-based system for listing species by the Committee on the Status of Species at Risk in Ontario (COSSARO);
-Increase user fees to achieve full cost recovery for implementation of the Endangered Species Act;
-Maintain mandatory habitat protection with no ministerial discretion and ensure that protection and recovery approaches are driven by science, not political interests;
-Close the door to options that would allow businesses to simply offset their harm to biodiversity by paying into a conservation fund or other actions unrelated to their activities.

I’ve personally seen too many activities where existing legislation was muzzled and not enforced. The strength of that legislation’s effectiveness relies heavily on everyone pulling their weight; if industry wants to let go of what they’re pulling so they can make more money, I understand the need to support economic development, but unchecked growth is the definition of a cancer. Don’t remove the checks and balances. Please, Minister, I urge you to strengthen the ESA, not weaken it, and to place more effort on actually enforcing the ESA’s tools rather than making them a box for developers to check.