A review of the Endangered…

A review of the Endangered Species Act is timely in light of the accelerating decline in the size of many species' population world-wide including in Ontario. The overall thrust of any review should therefore be to strengthen the Act, including increasing its effectiveness. Comments follow on each of the Areas of Focus in the discussion paper.

Landscape approaches

Both landscape ans species-specific recovery actions are required, case-dependent. Development proposals should always be assessed on a site-specific basis and not receive credit for attributes of a wider area.

The listing process

Colleagues who are closer to the COSSARO/COSEWIC process than I advise me that there is no need to make any changes to it. Most certainly, automatic listing without political interference should be maintained. It is fundamental to the integrity of the process.

Species recovery policies

The government should find ways to speed up the formulation of recovery strategies. The observed delays in Government Response Statements are consequential to the delays in coming up with strategies.

Reviews every five years also seems reasonable and should not be changed.

Identification of "regulated habitat" is an essential tool in many cases. It is the only way to create the potential for expanded habitat.

Authorization processes

Overall Benefit Permits are being handed out as if there is no tomorrow. Yes, applicants are made to jump through hoops, but in the end get what they want. Public comments appear to count for nothing. Whether the species is experiencing a real "overall benefit" remains murky. There is no accountability for the public to see. The process therefore comes across as a sham, and an expensive one at that.

Standardization of the criteria and mandatory implementation/results reports would be helpful.

Crown forests should not be exempted and the 2013 exemptions for other forestry, mining and development industries should be repealed.

Thank you for the opportunity to comment.