The review proposed of the…

The review proposed of the ESA makes me very nervous. It is positioned to sound like the protection of species at risk is first and foremost, but after reading the discussion paper, it is clear that economic development and making it easier to get through ESA regulations for developers and businesses is the main goal. We have a duty as Ontarians to protect our natural environment and species at risk. The environment has been destroyed by development in the past where loose regulations were in place, and by removing even more regulations, I fear that what is left of our environment will be degraded further. Every Ontarian benefits from the natural environment through clean air, clean water, erosion control, carbon sequestration/climate change mitigation and pure enjoyment of the beauty of nature. I am appalled to think that this government is trying to lead us down a road to make us believe that economic development and the interest of businesses will benefit us more than protecting our environment. Once species at risk are gone, we can not get them back. Do we want to leave a legacy of losing more species at risk than previous governments? Leaving regulations so weak that species and habitat are destroyed and gone with no opportunity for reversal? Be known as the government that gutted the ESA ?

There are certainly challenges with the implementation of the current ESA, but I do not believe the problems lie in the act itself. They lie in the regulation and implementation of the act. Over the years, the Ministry of Natural Resources and Forestry has been gutted to the point that they cannot keep up with the workload required under the ESA. To me, the solution should not be to streamline processes to make it easier, but to invest in more staff resources to properly dedicate to this important job.

I worry that landscape approaches are too broad scale and will overlook specific requirements of rare species. Each endangered and threatened species has unique requirements and habits. If we take a step back and try to look at it from a landscape scale, for example looking at the whole forest rather than the specific habitat requirement of an Acadian flycatcher which requires forest tracks with open understory. If we look too broadly at a forest and simply look at tree cover, we may ignore the fact that the understory of that forest is full of invasive shrubs like European buckthorn and honeysuckle which makes the habitat unsuitable for that species. By not taking a species specific approach, we risk losing species. Especially in high quality habitats with multiple species at risk, if we do not take a close enough look at each species, there will be important criteria overlooked.

When we think about the listing processes and protection for Species at Risk, there needs to be more transparency and clarity for the public when species are listed. It should be the governments responsibility to give public notice when species are listed. Allowing longer timelines for species to be listed is very risky and may end up being too late for the species. We do not have extra time to play around with. I am nervous about the idea that the Minister could remove protections for a species and its habitat. The decision to protect species and habitat should be based on science and field based studies. There should be no discussion around whether protecting the species will make it more difficult for businesses. I would like for protection to be based on scientific evidence from experts.

In terms of the length of time for government response statements being too short, I think the answer is clear. Hire more staff and put more resources towards creating the statements. This is a duty of the government under the Act, and finding ways to "streamline" the process sounds like a cop out. I do not believe that extending the response time will benefit species, since time is not on our side when it comes to species at risk. If we extend the timeline to allow for further study or if stewardship actions are likely to be completed over a longer timeframe, we risk waiting too long and not having a positive outcome for the species.

Finally I do not think that the idea of businesses paying into a conservation fund is appropriate in most cases. It seems like it will be an easy way to destroy the species and its habitat, while checking off a box to say that the paid into a fund for restoration elsewhere. There is no guarantee that the money in the fund will go to appropriate projects for the same species, or that the restoration works will be successful for the species they intended. This idea sets a bad precedent to say that habitat can be destroyed and simply installed elsewhere. It is much better to protect the habitat we already have than to make new habitat and hope that the rare species will find it and benefit from it.If anything, a conservation fund should be a last resort for cases where a project must go on and all other options for protection and mitigation on site are explored.

Overall I do believe that there are improvements needed to the ESA, but mostly when it comes to how the Act is applied and regulated. I think more staff are required to implement it and work on it. I do not like the idea of streamlining or making things easier for businesses, because this comes at a cost to the species at risk. We do not have the authority to make decisions that could ultimately mean the end of a species in Ontario.