Thank you for the…

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. Rather, they would make it easier for industry and developers to destroy the habitats of our most vulnerable plants and animals. While I understand that this is being done to improve the business outcomes in Ontario, the irreplaceable ecosystem services and tourism industries that would be destroyed with the loss of vulnerable species have costs that are beyond comparison to short-term economic gains.

Species continue to decline even under the ESA, with one example being Ontario’s freshwater turtles, all of which are considered as Species At Risk (SAR). As such, any amendments to the ESA must support its purpose of protecting and recovering at-risk species. To ensure that these species do not become extinct due to our careless actions, it is imperative to:

- 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.

This review must be shifted to be more conducive to protecting the species that we rely on, which extends far beyond those that we hunt and fish. Taking a scientific approach to the ESA is the only way to ensure this, and evidence that shows the need for a more stringent approach cannot be ignored.