This document proposes …

This document proposes “regulatory changes that will offer more innovative and coordinated ways of helping species at risk impacted by development projects.” It suggests that developments that impact species at risk will have “the option to have the new provincial agency pool resources and determine the best way to protect and recover select species on a province-wide scale.” The proposal suggests that by having a larger fund, supported by proponents that harm species at risk, more resources will be available to protect species at risk. This does not make sense since the best way to conserve habitat and protect species at risk is to stop harming them. The rationale used to propose this fund is illogical.
The notion of conditional exemptions are because mitigation strategies are well known and understood. Therefore protecting through mitigation that works activity can be exempt from ESA requirements. However, the reason that species at risk are already threatened or endangered is because we do not understand what mitigation works. For example, long-lived turtle populations have not been studied long enough to know if any mitigation strategies support recovery of the species. Until there is scientific proof that the mitigation strategies work over the long-term, conditional exemptions will not work.
It is unclear how giving a proponent the option to pay into a “conservation fund” instead of completing beneficial actions for species impacted by those activities will protect the species. It seems that this proposal will allow destruction of habitat and species at risk provided the fund is supported. It would be useful if the proposal identified the experts that access the new provincial agency pool. The proposal should consider making the fund available to only third party experts and not the proponents that pay into it because of conflicts of interest. Recipients of Species at Risk Stewardship Program compete for limited funds. This proposal suggests that this new fund will get projects that benefit species at risk underway faster. It would help if the proposal gave specific examples on how it will make things work faster and better. The proposal does not explain how much more money is expected and for how many more people.
It is curious that two species in this proposal are Eastern Whip-poor-will (Antrostomus vociferus) and Populations of Blanding’s Turtle (Emydoidea blandingii) within the Canadian Shield physiographic region. These are two species that were identified in an environmental assessment for a quarry permit application in Northern Ontario. A scientific paper was published that determined that the “densest” Blanding’s turtle population in Canada is on the proposed quarry site. Interestingly, the site is located “within the Canadian Shield physiographic region”. The co-incidence that 2 of 6 species in this proposal allows the quarry proponent a “conditional exemption” for these two species is remarkable. Will the new fund be used to protect this population of Blanding’s turtles or will this fund get bigger because there will be many destroyed turtles contributing to the fund. This proposal does not seem to have the intent of “conservation”.