As a conservation biologist,…

As a conservation biologist, I am very concerned that the proposals set forward in the ESA review discussion paper will not protect Species at Risk. For ten years, I have waited for this review in the hopes that it would tighten loopholes that enable destruction and degradation of Species at Risk and their habitat. Now that this opportunity is upon us, I am incredibly disappointed to see so many allowances that make it easier for applicants to destroy Species at Risk habitat.

Any amendments to the ESA must support its purpose of PROTECTING and RECOVERING Species at Risk, not be an enabling tool to keeping industry and developers happy. Regarding the ESA review discussion paper, I urge you to:

1. Repeal the 2013 exemptions for the forestry, hydro, mining and development industries;
2. 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;
3. Maintain COSSARO’s current science-based listing process;
4. Maintain mandatory habitat protection with no ministerial discretion; and
5. 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.

If MECP doesn't feel the current ESA is working well enough, why not try implementing some of the "broader ecosystem" approaches enabled by the current legislation? Why is every recovery strategy and every ESA permit issued on a single-species basis? Strengthening the holistic approach, through habitat stewardship and multi-species recovery plans, makes more sense than the amendments currently proposed.

We need biodiversity. We need all the plants, animals, fungi, and other organisms that call Ontario home -- and they need us to speak for them when their habitat and very existence is at stake.

Don't mess up for another 10 years, MECP. EXTINCTION IS FOREVER.