As a biologist working in…

As a biologist working in the environmental consulting and engineering sector for the past 6 years, I have had a first hand experience in the implementation of the Ontario Endangered Species Act. I believe the strength of the ESA has had successful outcomes for protection of Species at Risk (SAR) and conservation of their habitats. It has forced many developers to create compensation habitat and avoid impacts on SAR; I believe protection of SAR is important and should continue in the future. I do not think businesses should be allowed to destroy or negatively impact SAR habitat in order to improve the economy; conservation of SAR should be the top priority.

However, to find efficiencies and improve certainty for businesses in the implementation of the ESA I have the following suggestions:
- ensure consistency between the various MNRF districts or MNRF/MOECP staff. We have experienced some cases (especially with assessment of SAR bat habitat) where there has been inconsistent approach between various MNRF staff.
- develop standards for acceptable levels of effort in assessing SAR habitat through ecological studies / standard protocols
- for SAR bats, an ESA registration option should be developed (similar to Bobolink/Eastern Meadowlark): for example, if the proponent is planning to remove x hectares of treed habitat or less, then they should be able to do a registration, provided that the removals occur outside the bat active period, and with the area cut-off based on a review of current science. Or if the proponent is removing a certain amount of forest and SAR bats have been confirmed through acoustic monitoring, then they can register and install a certain number of bat boxes.
- the number of MOECP staff assigned to ESA implementation and reviewing development applications needs to be increased, to improve the speed of responses. We have had to wait months for review of our reports or responses to our reports; this creates challenges and delays for businesses or increased costs for tax payer funded projects (like MTO projects or environmental clean up projects).