Any amendments to the ESA…

Any amendments to the ESA must support its purpose of protecting and recovering at-risk species. As a professional biologist, I respectfully submit these comments for consideration:

· Consider cumulative effects of development on a landscape level when considering the impacts of development on Species at Risk

· Maintain and enhance the principle of protecting species at risk and their habitats as the primary objective of the ESA, and not being driven by economic development

· Consider and track the cumulative impacts of development on a Species at Risk

· Remove provisions under the Fish and Wildlife Conservation Act to allow harvesting or hunting of species listed under the ESA (i.e., Snapping Turtle, Algonquin Wolf), unless for cultural or Indigenous purposes

· Provide clarity into the role that MECP will play in administering the ESA in conjunction with the MNRF

· Develop a public registry of authorizations under the ESA (i.e., threats to health and safety permits) and increase enforcement, follow-up and review of these permits by the MNFR to ensure harm to SAR is minimized (the intent of the authorizations)

· Amend the ESA to allow for MNFR enforcement officers the power to conduct inspections of registered activities to ensure compliance with permit-by-rule conditions

· Improve service times for permits applications under the ESA by increasing resources (funding, personnel) to the MNRF to review and advise on permit applications

· Create a professional registry and standards for professionals those who have the expertise to assess impacts to SAR, including a code of ethics (i.e., similar to certified Butternut health assessor or Ontario Wetland Evaluator

· Amend section 57 (1)1 of the ESA so that exemptions will only be allowed if they do not jeopardize the survival and recovery of endangered and threatened species;

· Maintain COSSARO’s current science-based listing process;

· Increase and enhance the ability of the MNFR to provide oversight, enforcement, and compliance with the ESA to ensure species at risk are being protected under the act

· Ensure that development of a habitat regulation is for the best interests of the species, not on an economic development basis

· Maintain mandatory habitat protection with no ministerial discretion apply, remove or temporarily delay protections for a threatened or endangered species, or its habitat.) and

· Maintain the requirement for proponents of harmful activities to provide an on-the-ground overall benefit to species impacted