Hello, I implore the Ontario…

Hello,

I implore the Ontario Government not to weaken the Endangered Species Act (the Act) by making revisions to it. Species-at-risk are at risk in large part due to habitat loss and the Act needs to improve habitat protection, not weaken it to development.

The Government should instead focus on how to better protect the species-at-risk by improving how the Act is implemented and enforced. More focus should be on protecting these species-at-risk and their habitat and ensuring their recovery. If any changes were to be made to the Act, I would only request that the exemptions for major industry groups like forestry, mining and agriculture be removed.

My other comments as they relate to the 10th Year Review Discussion Paper are as follows:

This discussion paper does not provide much information in the review process that's transpired over the past 10 years nor does it provide context or evidence as to why and where the 'Challenges' have derived from.

Area of Focus 1:

The landscape approach is not explained well.
Habitat of species-at-risk can be interconnected and a landscape approach with broad-species focus would be helpful for habitat and species. These tools are already included in the Act, but should not replace a species-specific focus.

Area of Focus 2:

There should NOT BE a different approach or alternative to automatic species and habitat protections. Listing a species at risk or their habitat should be based on sound research, scientific evidence and as informed by COSSARO's review. A species/habitat, if deemed 'at risk', should always be listed and the listing should have nothing to do any other outside influence. This Act is FOR species-at-risk, if anything, improving the communication with affected stakeholders that may be impacted would be beneficial.

Allowing Ontario Scientist to sit on COSSARO is encouraged.

Area of Focus 3:

The Act is for the protection and recovery of species-at-risk. If a species is listed, already they are in peril and there should be no extension to the timelines. Changes to the legislation timeline will not improve the Government Response Statement challenges.

The Government Response Statement and the development of the recovery strategies should better be coordinated and recovery strategies should be created for multiple species that share similar geographic areas or which face similar threats. Again, coordinated efforts in how the current Act is implemented would be more beneficial than changing the Act itself.

Habitat regulations should not be changed.

Area of Focus 4:

The Act should only focus on the protection and recovery of species-at-risk and their habitat.

There should not be conservation banking or paying into a conservation fund or anything to that affect. These species and their habitats are at-risk likely because their habitat is already compromised. Habitat needs to be protected and allowing activities to be conducted where there's critical habitat in lieu of a payment is backwards and is unacceptable. Instead, there should be the focus on habitat protection for species-at-risk which in turn would also benefit the rest of the ecosystem.

As a species declines, the more an effective strategy is require and the more this may cost. It would be beneficial to ensure appropriate protection at the onset of a species being listed. There should be no delays.

Early identification of the needs of the species that may be impacted during the planning phases of development should be discussed with the stakeholders and expectations of how best to protect them and their habitat should be communicated and understood.

If changes are to be made to the Act, removing the regulatory exemptions for activities that can have the most negative affects on species-at-risk should be considered. As well, how the Act is implemented and communicated could improve species and economic outcomes, but the protection and recovery of species and their habitat should not, in any way, be sacrificed for economic benefit.