Re: EBR 013-4143 Thank you…

Re: EBR 013-4143

Thank you for the opportunity to review and comment on the 10th Year Review of Ontario’s Endangered Species Act

We support the continuation of a scientific-based approach to the listing of species at risk (SAR) without the addition of any Ministerial discretion. A scientific approach ensures that politics and special interests will not weaken the protections needed for these species.

The current time limit of nine months to develop a Government Response Statement is not too short; in fact, the short time frame reflects the need for the government to act quickly to protect any SAR. The need for “additional engagement” or additional time is not a reflection of the process being too quick, but of a lack of resources and manpower in the responsible Ministries. Instead, funding to MNRF and MECP should be increased to the levels necessary to properly operate and engage stakeholders to develop the Government Response Statement in the allotted time.

We also support the requirement that any harmful activities are mitigated though the implementation of an overall benefit plan, and not banking on the contribution of cash for possible compensation in the future. Delays in implementation are necessary to ensure harmful impacts to SAR are reduced or removed. We do agree that there is a problem with the process that needs to be corrected. As mentioned in the 2017 Environmental Commissioner of Ontario report, “the MNRF has never denied a permit to harm a threatened or endangered species”. It would be naïve to believe that none of those activities caused any permanent harm to SAR or their habitats, or that there are sufficient resources in the MNRF, now MECP, to properly monitor or enforce these activities. Further, any exemptions for industries such as forestry, mining, or hydro should be repealed as these industries can impact large areas of SAR habitat, and quickly undermine any work being done to protect these species.