I am an ecologist and work…

I am an ecologist and work for a consulting company that regularly implements the ESA on projects for the provincial government (i.e., MTO) and private developers. I support the review of the Endangered Species Act, there are opportunities for improvements, but the tone of the Discussion Paper concerns me, as it seems that the primary intention of the review is to reduce the barriers to economic development. While pro-business constituents can voice their opinions through this review (and other means), I ask you to listen to those that speak on behalf of the plants and wildlife that cannot and do not have the same financial backing to make their voices heard loudly. I am even more concerned that these voices will not be clearly heard given the recent dismissal of Ontario’s Environment Commissioner. The protection of our plants and wildlife is critical – strong mechanisms are required to ensure their protection. I see it ALL the time – if it costs more money to protect them it will not be done unless it is required, but these actions do not reflect what we all actually need. Unfortunately, our society does not have the understanding of the great importance of the protection of our environment of which SAR are a component, in order to take action that support our environment for the benefit of all. Until then, strong legislation and regulations are needed to ensure their protection. Voluntary efforts, and nominal stewardship incentives are not enough.
I also note that there is no indication that there has been a review to determine whether or not the ESA is currently effective at protecting and recovering species at risk. This should done to critically assess the need for changes to the ESA, and to demonstrate how any proposed changes are intended to improve protection and recovery (including a measure of certainty of the anticipated success of those changes).
Landscape Approaches:
The design of any landscape approaches needs to be made with the intention of species protection and recovery, and it needs to be overseen at the landscape level (this is expected to require government staff to oversee it). The ESA is implemented on a project or site by site basis. It is very difficult (maybe impossible) for an individual project to assess its relative contribution to the overall harm or protection of a species, as this is just a snap-shot in time, and the landscape is changing with many other projects being concurrently completed.
There is certainly value in the creation of recovery strategies at the landscape level in certain situations. For example where there are multiple species using a landscape that may have competing protection requirements.
Listing Process:
I understand that automatic species and habitat protections can contribute to uncertainty, but I do not support ministerial discretion on whether to apply, remove or temporarily delay protection for species or their habitat. While it sounds like some flexibility would be beneficial as the implications of listing of species can vary, I do not trust the ministerial staff and politicians to make this decision, especially without the Environmental Commissioner’s oversight.
I also do not support a transition period to listing of species or their habitat because of the likelihood that it will actually result in much more harm to SAR and their habitat during the transition period to avoid potential regulations. We’ve seen this in many other cases (i.e., clearing of woodlands during the development of Significant Woodland definitions in some municipalities to avoid the potential protection of these features).
It is necessary that the listing process be a scientifically based approach. In practice this does not always appear to be the case. COSEWIC has a much more robust scientific review of SAR listings, this reflects the investment in the staffing of this committee. COSSARO could be improved with better funding for staffing of the committee.
Species Recovery:
Extending the government response period of nine months for recovery strategies and management plans needs to be clearly justified and the government needs to ensure they have sufficient staffing to undertake and develop these strategies and plans in a timely manner. It does not currently appear that there will be enough ministerial staff to complete the work load required, given the anticipated reductions in staff.
Authorization Processes:
The question of whether conservation banking is an option requires demonstration that this has been successfully implemented elsewhere (measure of success requires benefit to the species), and that it directly applies to the situation and species in Ontario. I am very reluctant to support this, on the ground recovery actions are necessary to offset any impacts to SAR.

I would like to see that there has been rigorous review to justify any proposed changes to the act and that any changes prioritize the intentions of this Act, which is to protect and recover at risk wildlife.