Thank you for the…

Thank you for the opportunity to comment on the discussion paper on the Endangered Species Act (ESA). Ontario is home to over 200 species at risk, with many taxa still not thoroughly reviewed. The ESA was created to protect species, and the legislation has been used to do so since its implementation in 2008.

Area of Focus 1-Landscape Approaches
Recovery activities focusing on specific landscapes or ecosystems can be beneficial for numerous species. However, this approach must be species dependent and decided by experts, as certain species at risk require very specific recovery strategies (e.g. Butternut canker).

Area of Focus 2-Listing Process
I disagree with any change to the automatic listing of SAR after review by COSSARO. As the panel is comprised of up to 12 experts using the best available science along with TEK, their decisions are sound. I do not believe that the COSSARO review an assessment process requires any change or delay.

Area of Focus 3-Species Recovery Policies
As opposed to delaying Government Response Statements, I believe that a commitment should be made to publishing recovery strategies and other recovery documents in a timely manner. The Spotted Turtle is an example of a species that was assessed as endangered when the ESA took effect in 2008 and a provincial recovery strategy has yet to be written.
Conducting 5-year assessments of progress on recovery are essential. They not only allow us to use the documents that took numerous hours and tax dollars to create and review but to use current scientific literature to determine if the species are continuing to decline.
I believe that habitat regulation is not required for all species at risk but this is a topic that should be handled on a case by case basis and decided by experts on the species being considered. Species with very few populations in Ontario should have mandated habitat regulation as they are the most vulnerable to future habitat loss and development pressure. I also believe habitat regulation in the Carolinian zone be mandated given the lack of natural habitat left in this area.

Area of Focus 4-Authorization Processes
I encourage the government to develop standard overall benefit actions that provide a tangible benefits to the species in question and an overall benefit to the species on the ground as opposed to research funding.
I strongly oppose the changes to obtaining a D permit. This is a last resort where there is overwhelming social or economic benefit and the obtaining of a D permit should not be handled lightly. In the case that a D permit is granted, the mitigation expended on SAR should be significant.
Forestry under Ontario’s Crown Forest Sustainability Act should not be exempt from the ESA. Crown land should be protecting habitat for species and permitting public access to these natural areas.

Aboriginal Significance
In indigenous communities throughout Ontario, animals and plants have various cultural and spiritual values. The ESA recognizes these beliefs and works with First Nations communities in order to protect these species and the habitats they live in. The strength of the current ESA allows for this and any changes to lessen the protection of species at risk would negatively affect the species themselves and the first nations communities that rely heavily on them for medicines and food sources and their cultural and spiritual values.

Economic Benefits
The habitats species at risk reside in provide economic benefits to nearby cities. As an example, wetlands prevent major flooding, filter water and indirectly provide food sources as species such as bear, waterfowl and moose rely on wetlands as food and water sources (EPA 2006).

In summary, I strongly support the current ESA. It is a powerful piece of legislation that can protect our rarest species and the habitats they live in. I strongly disagree with any proposal to change the ESA that would weaken this. If anything were to be changed, a more rigorous process should be created by the government preceding the approval of an overall benefit to ensure that the species affected are truly receiving an overall benefit. Sustainable developments and conservation are possible, but require more work upfront to ensure species protection as well as economic benefits.

EPA. 2006. Economic benefits of wetlands. Retrieved Feb, 07/2019 from: https://www.epa.gov/sites/production/files/2016-02/documents/economicbe…