Dear Minister Phillips, Cc:…

Dear Minister Phillips,
Cc: Environmental Registry of Ontario
Cc: Peggy Sattler

Re: 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, 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 support protecting and recovering species by looking at the entire landscape and taking actions that will contribute the most to improving habitat and protecting species from harm; however, care must be taken to ensure the individual needs of each species are still taken into account. There are situations where a species-specific approach is still warranted.

The ability of the Committee on the Status of Species at Risk in Ontario (COSSARO) to determine the status of species, independent of government, is essential to the proper functioning of the Endangered Species Act (ESA). Improved communication and transparency in all aspects of species assessment and protection is warranted to provide clarity for the public and business. However this must remain a science-based process.

Habitat loss or degradation is a primary cause for most species’ decline. Automatic protection, combined with clear communication on where impacts can and cannot occur, would protect species while providing certainty of what to expect for economic development.

Delays and inaction are detrimental to species while at the same time providing little economic certainty since business is uninformed of the parameters under which they must operate. What is needed for species and economic development is for government to focus resources on quickly providing the framework for protecting habitat and taking action.

I am in favour of consistent application and streamlining of decisions, which must also include decisions to deny a permit for an activity that would harm a species or its habitat. Permits allowing harm to endangered species or their habitat poses considerable risk so need to come with strict conditions. Extinction is permanent.

Challenges should be addressed through improved planning and investment in communications, program development and staffing, not environmental deregulation. Many of the issues are not with them legislation itself, but with the implementation. The government must ensure that enough staff are available to study species, prepare reports and process applications in a timely manner.

Any amendments to the ESA must support its purpose of protecting and recovering at-risk species. To that end, I urge MECP to:

- 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.
- Ensure that the government continues to fund projects related to species at risk recovery

Thank you for your attention.
A concerned citizen
London, Ontario