Dear Government of Ontario:…

Dear Government of Ontario:

I strongly oppose any intention of the provincial government to reduce the efficacy and reputability of the Endangered Species Act in Ontario. I support its strengthening and further implementation to ensure all species at risk in Ontario are afforded stronger protection to individuals and their habitats. Southern Ontario habitat for listed species is subject to on-going disturbance, fragmentation and destruction via the authorization process for land use conversion in the name of economic growth.

In response to some of the proposed amendments:

Species-specific assessment should remain the focal point of the permitting and monitoring process, and the protection of such specific species should be considered at various landscape scales to encompass multi-species when applicable (e.g. interior woodlands, aquatic and avian species of wetlands). Landscape approach is already enabled and considered in the current Act. Further implementation of this strategy should be supported and provided increase resources.

Ministerial discretion is NOT equivalent and should NOT replace science-based and Traditional Ecological Knowledge. Ministerial discretion should not be included in amendments to this Act concerning the listing of species. Increased transparency for the listing mechanisms is recommended.

The Open for Business agenda of the current government should not have any association with the recovery and protection of Ontario's biodiversity. Flexibility for economic activity should not be further investigated.

Meaningful recovery actions need to be strengthened. Critical habitat needs further protection and authorizations for the destruction of critical habitat should not be permitted in the name of economic development or land use conversion to residential use.

Overall Benefit Permitting requiring Net Gain needs to be further implemented rather than reversion to "minimizing harm" permits. Compliance enforcement and monitoring needs to be increased.

A pro-active approach to Overall Benefit Permitting and habitat protection should be considered. Such an approach would include habitat compensation prescriptions, pre-determined, ready to be used when Authorizations to destroy are granted. For example, a standardized rate for SAR bat habitat loss and compensation measures (the number of bat boxes, bat condos, enhancement foraging habitat) should be established to increase the efficiency of the authorization process for both the developer, its proponent and the Ministry.

Further analysis on the effectiveness of the Overall Benefit Permitting and the status of listed species is encouraged. Case study examples from proven legislation and policies in other parts of the world, including the United States and European states, should be evaluated for efficacy and applicability.

In the spirit of the previous UN Decade on Biodiversity, Ontario has a global responsibility to conserve biodiversity. In the spirit of the next UN Decade on Ecosystem Restoration, habitat for species at risk needs only to be enhanced and restored, not further degraded, fragmented, or destroyed.