I am taking the position…

I am taking the position that the government is interested in consulting on this matter in good faith for the benefit of our democratic ideals (See Arnstein’s Ladder of Degrees of Citizen Participation (1969). As outlined in the purpose of the review – the enabling of positive outcomes for species at risk – I offer the following comments for your consideration.

The current status of endangered species in Ontario is not good. The necessity to strengthen existing provisions respecting legislation/regulation for species at risk are found in numerous indicators:
- Provincial government papers documenting the challenges confronting the protection of SAR – see the Biodiversity Council’s strategy paper (2010), and then 5 year monitoring report (2015) i.e., increasing numbers of species on the list.
- As documented by the federal government, there is poor performance overall of our system to protect SAR. The Ontario landscape has a diversity of ecosystems where SAR are found – forests, grasslands, wetlands, lakes (most notably the Great Lakes) and rivers; and costal areas. See
http://www.oag-bvg.gc.ca/internet/English/parl_cesd_201311_e_38658.html
- Poor overall ecological condition circumstances are found in many of the watersheds of southern ON as detailed in Watershed Report Cards compiled by Conservation Ontario.
- the ECO has documented extensive issues with the current SAR regulatory system, and these are spelled out in the Annual Report to the Legislature in 2017.

There are currently 248 species (and species populations) that are listed as being at risk under the ESA of ON. The government needs to do its part to protect the rich biodiversity of our province and not let individual species slowly die out for the sake of short term economic interests.

To this end, I support amendments to the ESA that are intent on improving the protection and recovery of at-risk species. To accomplish this, the government should enact the following mechanisms:

- Repeal the 2013 exemptions for the forestry, hydro, mining and development industries;
- 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;
- Maintain mandatory habitat protection with no ministerial discretion; and
- Maintain the requirement for proponents of harmful activities to provide an on-the-ground overall benefit to species impacted with no backdoor option to simply pay into a fund to compensate for harm.

The commenter acknowledges there are challenges with the current system, and adjustments are required dealing with regulations/procedures. My suggestions outlined above are directed towards this endeavour. In addition, more concrete actions can be derived by implementing findings from research that protect endangered species with targeted programs and financial incentives to implement environmental stewardship, e.g., ALUS program in agriculturally-dominated landscapes. In addition, new employment opportunities are available in areas of research and environmental stewardship to understand and then implement improved protection mechanisms for SAR. Landscape-wide studies should be supported and implemented, e.g., Carolinian Canada’s Big Picture strategy for connecting natural heritage areas together in southwest Ontario.

Thank you for offering me the opportunity to comment on this important topic on behalf of my family and future generations. The value of nature is often taken for granted or not placed in a central place of our society. I am very worried with the general emphasis of the current government in thinking short term economics over long term societal/environmental sustainability. I offer the following quote as a summary thought on this: “it’s important to practice environmental stewardship but not at the cost of our economy (Andrea Khanjin, parliamentary assistant to the ON Minister of the Environment), Source: Town of Erin's Mayors Breakfast Meeting, January 31, 2019.