Listing of species at risk…

Listing of species at risk by COSSARO and automatic protection of listed species and
their habitats are cornerstones of the ESA and the Ontario government already has opportunity to provide scientific input through representatives (MNR etc employees that have relevant expertise) to COSSARO. A second round of political second-guessing by politicians, political staffers, and upper management will add uncertainty, delays, and inappropriate interference, and controversy.

Edge of range species should not be denied protection based on their status outside Ontario. All conservation is ultimately local and Ontario should work hard to maintain all the species that naturally occur here regardless of how many naturally occur elsewhere.

Species and their habitat should be protected at listing. Allowing the Minister to remove or delay protections is inappropriate and invites political meddling.

I do not support weakening of legislated timelines for preparing recovery documents. There should be no change to the legal requirement to produce GRS within nine months
of the release of Recovery Strategies or Management Plans. Failure to meet the legislated deadlines
is a chronic problem, which should be addressed through improved implementation, not weakening
of the law.

There are already sufficient tools for authorizing harmful activities. No new tools are needed.
Challenges should be addressed through improved implementation.

Proponents of harmful activities should NOT be allowed to simply pay into a fund rather than
providing on-the-ground reparation for damage done. This easy way out reduces accountability and
facilitates harm to species at risk and their habitats. Retain the current requirements to provide an
on-the-ground, overall benefit to species harmed. Proponents already tend to claim that destroying a single population does not substantially increase the risk of extinction and this sort of thinking could be entrenched further under the guise of a bigger picture perspective. At the policy level, this attitude is absurd, akin to planning a diet of chocolate bars on the grounds that a single one won’t cause obesity. Policy making is the opportunity to curb this type of short-term rationalization rather than entrench it.

Do not remove the requirement to obtain Cabinet approval or to consult with an independent expert regarding sec. 17(2)d permits. These are intended to be available only for projects that “result in a significant social or economic benefit to Ontario” and that will not “jeopardize the survival or recovery of the species in Ontario.” These are appropriate requirements and ensure that such permits are issued only an exceptional basis.

Do not remove the requirement for the Minister to seek an independent opinion on regulations that
might jeopardize the survival of a species in Ontario. That would only make it easier for harmful
activities to proceed, without proper scrutiny.

The ESA (sec. 18) provides a means to harmonize its requirements with other legislative or regulatory frameworks, based on the standard of providing an overall benefit to species negatively impacted.
Unless this standard is maintained, species will continue to decline.