Thank you for the…

Thank you for the opportunity to submit a comment on the discussion paper “10th Year Review of Ontario’s Endangered Species Act”. I have organized my comments by Focus areas.
Focus area 1: No comments
Focus area 2:
• I do not support increasing the timeframe for adding SAR to the ESA list; some species can become at-risk quickly and therefore need protection quickly; there are already lengthy processes in place at the federal and provincial levels before SAR are added to the ESA.
• I believe that BOTH species and habitat protection for END and THR species are appropriate given the scientifically-proven threats to these species.
Focus area 3:
• While I believe that increasing the timeframe for adding SAR to the ESA list, extending the Government Response Statement period when additional engagement with Indigenous peoples and conservation groups is required may be acceptable. There should be a transparent process for any extensions of the Government Response Statement timeline.
• I do not believe that consultation with business interests is appropriate in the development of Government Response Statement to ESA recovery strategies, as businesses may be biased against the preservation of END and THR species and/or their habitat.
Focus area 4:
• I believe that the authorization tools in general are important, however that conservation (i.e. avoidance of harm) should remain the top priority over mitigation and compensation measures.
• I do NOT support cash-in-lieu / conservation banking / habitat offsetting approaches unless appropriate studies have been conducted to ensure that these approaches will be effective for the SAR targeted. Often SAR require specific and/or complex habitat which is very difficult to re-create, and/or individuals in a population may return to the same site every year and will not necessarily find new habitats.
• I believe that oversight by Agency staff (MNRF / MECP) is important and should continue; self-enforcement of SAR policies (i.e. by registering an activity and then having no post-registration check-ins on projects or progress) poses too many risks of non-compliance.