I am writing on behalf of…

I am writing on behalf of the Greenspace Alliance of Canada's Capital regarding the 10 year review of the Endangered Species Act.

First, we would like to signify our support for the submission made by Ontario Nature, available on their website (see link below).

We also support the submission made by the Ottawa Field Naturalists' Club (see pdf document attached).

From our own experience in working to preserve and protect greenspace in and around Ottawa, our main exposure to the ESA has been through the Overall Benefit Permit. In general, we have found these to be not at all beneficial for wildlife, and extremely destructive of habitat. We are not alone in coming to this conclusion. The Environmental Commissioner of Ontario dedicated a whole chapter of her 2017 report to this subject; “With each passing year, the extent of this failure becomes more clear — the ministry has reduced what should have been a robust system for protecting species at risk to what is largely a paper exercise,” her report says. “The MNRF is failing to not just protect species at risk as intended under the law, but also to lead effective recovery programs. In the best case, the MNRF has created a system that leaves itself with a minimal role to play; in the worse case, it has a created a system designed to fail.”

The Overall Benefit Permit allow proponents, in the actual wording of the permit, to "kill, harm and harass" a species at risk "as well as damage and destroy the habitat of the species at risk for the purpose of the development", in exchange for things like putting up fencing, building alternative nesting sites and contributing to research on the species at risk. The "overall benefit", if measured at all, is computed over the entire Province of Ontario. So a species can well be extirpated and its habitat destroyed in its native range on the theory that somehow the actions taken will improve the SAR population overall. This is pretty much a fiction and real habitat protection is required.

The presence of SAR should be a trigger to protect and expand natural habitats, not lead to its destruction. As we are facing a climate emergency, a climate lens should be applied to these applications instead, with a goal of expanding wetlands and forests as carbon sinks to help stabilize the climate.

To achieve this aim, we would propose that the Overall Benefit Permit be renamed to reflect what what it really is, the SAR Habitat Destruction Permit, and to severely restrict their issuance, maybe even invoke a moratorium, while we try to deal with the climate crisis that is hard upon us.