EBR 013-4143: 10th Year…

EBR 013-4143: 10th Year Review of Ontario’s Endangered Species Act
Thank you for the opportunity to comment on the ESA review discussion paper. Though I support the stated intent to provide more stringent protections for species at risk, I am not confident that the proposals being considered will not accomplish that goal. On the contrary, for the most part they would make it easier for industry and developers to destroy the habitats of our most vulnerable plants and animals. I would support revising the process to make it clearer and more efficient. However, any efficiencies should not equate with less protection for species at risk.
Any amendments to the ESA must support its purpose of protecting and recovering at-risk species. To that end, I urge MECP to:
- Repeal the 2013 exemptions for industries that do not have a comprehensive planning process in place to deal with issues surrounding species at risk (presently this would only include forestry which has a regulated forest management planning process that deals with the ESA);
- 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 (the list should be maintained by scientists and politicians should have not input into this 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.

Thank you for your attention to this matter.