To Whom it May Concern,…

To Whom it May Concern,

Throughout my environmental career, I have worked as an environmental consultant, held positions within the non-profit industry, worked in a permitting role at a conservation authority, and am now a faculty member at Fleming College. I have been involved with species-at-risk issues in all of these positions and appreciate the opportunity to comment on this proposal.

Throughout my career, I have watched as more and more species were added to the ESA. The ESA exists to protect species, primarily as a result of the impacts of human activities. The current proposal’s direction to providing an “open for business” approach to environmental law and policy is not something that I support.

The transparent science-based listing of species by COSSARO provides certainty for species that is justified by research. The species-specific listings are critical to learning more about SAR and help communicate this information with relevant professionals. Replacing these with a landscape-approach would not provide a scale of resolution fine enough to base law and policy upon.
Flexibility mechanisms for industry currently exist in the ESA. The options under consideration suggest an intent to make it easier for industry and development proponents to proceed with harmful activities. This direction is inconsistent with the purpose of the ESA which is to protect and recover species at risk. Of the flexibility mechanisms I have seen, more oversight – not less – is required to ensure that, for example, habitat compensation and artificial structures are being implemented as required.

Habitat regulations provide ease of implementation and enforcement and should not be changed. The inclusion of areas where species used to live or are capable of living provide much-needed options for species recovery actions and should not be removed from legal provisions.

Improving the implementation of the ESA is certainly worth considering, but not at the expense of the strong regulations in the ESA that help to protect Ontario’s species at risk.