Thank you for this…

Thank you for this opportunity to comment on the 10-year review of the Endangered Species Act (ESA; ERO No. 013-4143). However, I am concerned that the Discussion Paper is a thinly veiled proposal to remove existing protection for the growing number of species at risk in our province and make it easier for industry to continue to degrade and destroy habitat and species-at-risk directly.

The ESA exists to protect and recover species facing extinction in Ontario. Therefore, I support only the direct strengthening of this ESA by:

- Maintaining that every species gets assessed by COSSARO, and if necessary receives a science-based Recovery or Management Strategy, a Government Response Statement and a Progress Report within existing mandated timelines. Any "landscape approach" must exist over and above species-specific regulations.

- Maintaining science-based listing by COSSARO, and abandoning the idea of allowing ministerial discretion regarding habitat and species protection under section 9 and section 10 of the ESA

- Preventing any appeal process to COSSARO assessments and subsequent listing on SARO

- Requiring all proponents of harmful activities to provide an on-the-ground, monitored and enforced overall benefit to impacted species and abandoning your proposal to create an option for such proponents to pay into a conservation fund to compensate for conducting activities that are harmful to species at risk

I ask that you commit to actual strengthening the ESA by:

- Repealing the exemptions created in 2013 to permit forestry, hydro and mining industries to conduct harmful activities to species at risk

- Repealing the exemption created in 2016 to allow hunting and trapping of the Threatened Algonquin wolf

- Amending section 57 (1)1 of the ESA so that exemptions will only be allowed if they do not jeopardize the survival and/or recovery of Endangered and Threatened species

- Affording section 9 and section 10 protection to any species that has been assessed as Special Concern in two consecutive assessments by COSSARO until such a time when the species' assessment results in downlisting to Not At Risk