Thank you for the…

Thank you for the opportunity to comment on the 10th Year Review of Ontario’s Endangered Species Act: Discussion Paper, ERO number 013-4143. I look forward in seeing improvements to the effectiveness of the Endangered Species Act (ESA) and ensure a balanced approach between a healthy environment and a healthy economy.

The most important action the government must take is a permanent recognition of the Crown Forest Sustainability Act (CFSA) as an equivalent process to the Endangered Species Act (ESA) through a permanent Section 55 Regulation. The CFSA already provides landscape, stand, and site-level direction for managing, conserving, and protecting species at risk. Having two acts attempting to accomplish the same outcome represents the single greatest piece of red tape and duplication to the forestry sector.

Once this essential first step has been accomplished, below are other requirements that should be embedded in a new, modernized ESA:
1. Consideration of climate change on habitat in all species at risk policy
2. Cumulative impact of all species at risk policy on a healthy economy
3. Socio-economic impact analysis must be completed and shared with impacted stakeholders and First Nations prior to any species at risk policy being implemented

It is my understanding that the Ministry of Natural Resources and Forestry (MNRF) is responsible for species at risk prescriptions currently being delivered under the CFSA. I expect that unworkable prescriptions will be addressed and improved regardless of any future changes made to the ESA.

Further I am concerned about role of the Federal Government and potential negotiations with Ontario on Conservation Agreements. For example, a MNRF socio-economic analysis determined that up to 2800 jobs could be lost and 8 mills could close as a result of the province meeting the federal disturbance thresholds for caribou. It is our expectation that Ontario will consult with impacted stakeholders and First Nations well in advance of any draft and will not enter into a Conservation Agreement with the Federal Government that will result in lost jobs and lost opportunity.

In order to avoid serious socio-economic impacts, we need permanent recognition that the CFSA is an equivalent process to the ESA, while developing workable species at risk policy, and sending a strong message to the Federal government that Ontario will manage our own resources.

Sincerely,

Tom Darechuk