I am strongly opposed to the…

I am strongly opposed to the proposed changes to the Endangered Species Act (ESA). Not one revision outlined in this document will improve the protection of Species at Risk in Ontario and their habitats. When read thoroughly, it is clear that the only intent for this review is to make the development process easier for developers and businesses so they can continue to make large profits. If the suggestions in the review are approved, this can be devastating to the Species at Risk (SAR) in Ontario. Studies show that 60% of global wildlife populations have declined since 1970; this is a time to strengthen our protection strategies, not loosen laws. I am a Terrestrial Ecologist with knowledge and experience in this subject, and I feel that my comments should be considered. I will include comment on some examples pulled directly from the review.

In regards to “The Landscape Approach”, the Review states: "The case-by-case and species-specific policy approach to implementing the Endangered Species Act can sometimes limit the ability to achieve positive outcomes for species at risk."
Although it is true that a landscape approach could be beneficial to protecting SAR habitat, it is absolutely necessary that we evaluate local and immediate areas where development projects will take place. If a SAR or their habitat is present at a proposed development site, the area should be protected regardless of habitat outside the project area. We cannot dismiss the case-by-case approach and replace it with a landscape approach, they need to be used collectively. The entire purpose of the ESA is to protect SAR species from becoming extinct, and if we don't protect them in every case, how can this be successful?

For changes in regards to the Listing Process and Protections for Species at Risk, the Review states "In some cases, automatic species and habitat protections can contribute to high uncertainty and costly impacts to businesses and the public."
Once again, this review is favouring short-term economic gain over the long-term protection of our species. The decision to list a new at-risk species needs to be based on the expert knowledge and experience of scientists, not politics.

Currently, the first purpose in the ESA is “To identify species at risk based on the best available scientific information, including information obtained from community knowledge and aboriginal traditional knowledge." Delaying the listing process would go against one of the main purposes for the ESA. The public does not need to be notified when a species becomes listed; a plant or animal that is at-risk of becoming extinct simply does not have time to wait. We must take immediate action so we can begin working on recovery strategies and action plans. Remember, these species are at risk of becoming extinct.

Protecting species at risk and their habitats can have enormous value to human beings as well. For example, wetlands that are habitat for many SAR turtles provide many ecosystem services that humans take for granted. Wetlands filter water, prevent floods, store carbon, provide educational and recreational opportunities, etc.

In conclusion, this proposed review will be detrimental to humans, and plant and animal species residing in Ontario. Humans repeatedly exploit our resources at a rate that is not sustainable, and only once when situations are past the tipping point do we try to correct it. Let’s make the right choice and protect our species at risk while they are still with us and it is possible. Many people in this province value our natural areas and wildlife, and we are very lucky to have such a wide diversity of species. Their extinction should not be made in the favour of a few large corporations.

Thank you. I beg you to please reconsider this proposal.