Concerned Citizens of King…

Concerned Citizens of King Township
Box  875, King City, Ontario, L7B 1A9 www.cckt.ca
March 4, 2019

Ministry of Environment, Conservation and Parks
Minister Rod Phillips.

RE: ERO #013-4143: 10th Year Review of the Ontario Endangered Species Act.

Introduction
Concerned Citizens of King Township (CCKT) is a well-established citizens’ group which has been active in King Township for 48 years. CCKT represents approximately 150 households. CCKT advocates for sound progressive planning, well-planned thriving communities, preservation and enhancement of natural heritage systems, protection of waterways and prime farmland, and engagement of citizens in public consultation.

CCKT would like to highlight two key points / principles:
1. The purpose and goals of the Endangered Species Act.
2. Key proposed changes.

Purpose and Goals of the Endangered Species Act.
The purpose and reason for the drafting and approval of the Endangered Species Act (the Act) in 2009 were to recognize and protect species-at-risk in Ontario, and to take actions to protect the species in its native habitat and to improve the health, status and numbers of each species.
The purpose of the Endangered Species Act is not intended to streamline planning approvals and support economic development. These matters are best addressed in other provincial legislation.
It is clearly understandable that implementing the policies of the Act will result in hurdles and challenges for specific planning and development applications which are tied to economic development. Ontario has implemented a number of forward-looking policies which protect wetlands, water courses and other significant natural heritage features often through buffers and protective linking zones. Of course all of these will put some limitations on planning and economic development proposals, but all for good long term purpose.
CCKT recognizes the importance of economic development approvals which are part of forward long term planning which also are carried out while meeting the significant purposes and policies of the Endangered Species Act, Oak Ridges Moraine Conservation Act and other legislation intended to protect and enhance natural heritage systems and the many species-at-risk which live and thrive in these protected areas.
We ask that Ontario keeps its focus on the intended purposes of the Endangered Species Act, and not view the Act as an impediment to economic development, and thus diminish the strength and purpose of the policies which are intended to protect species-at-risk and help each species thrive.
Proposed Key Changes to the Endangered Species Act
CCKT supports the several of the desired outcomes of the proposed changes to the Act, specifically: Enable positive outcomes for species at risk; Ensure species assessments are based on up-to-date science; Address multiple objectives for ecosystem management through stewardship and protection activities; Increase efficiencies in service delivery; Provide clarity for those who need to implement the Act; Maintain an effective government oversight role.
CCKT raises strong concerns about the focus and related changes that seek to steamline the process, reduce the cost and take away barriers for economic development. Of course if there are opportunities to reduce unnecessary time and financial costs while completely maintaining the integrity of the purpose of the Act in enabling positive outcomes, these should be pursued. However, there should be no compromise on the intended purpose of the Act in order to foster economic development.
CCKT intends to provide additional comments on the four key areas of focus in the Discussion Paper when the draft document with the proposed changes is released.
Thank you for your consideration of our submission.

Sincerely, J. Bruce Craig
Chair, Concerned Citizens of King Township