1. The overall direction of…

1. The overall direction of the ESA review appears to be environmental deregulation, which is counter-productive to the very core of the act and what it intends to achieve.

2. The options under consideration undermine the very cornerstones of the law. We required a robust and enforced ESA, including: science-based listing of species at risk (including Indigenous Traditional Knowledge), mandatory protection of threatened and endangered species and their habitats, and legislated timelines for planning and reporting.

3. Do not compromise the science-based process for listing species at risk is in jeopardy by allowing alternative based non-scientific decisions to alter the survival of species.

4. Please do not allow the protection of species at risk and their habitats to be left up to the Minister.
As shown over the years, our governments are heavily influenced by wealthy lobbyists. Such changes would leave our most vulnerable plants and animals subject to political whims and the influence of powerful industrial lobbyists. Conservation cannot be political.

5. Do not weaken requirements for authorizations to undertake harmful activities. Economic development can continue without compromising conservation.

6. Do not replace harmful permitted activities with the proposed “conservation fund” as this could be an easy-way-out for proponents. This option would make it easier and more likely for harmful activities to occur and will do nothing to protect our at-risk species and habitats.

7. Do not permit broad authorizations for harmful activities. Landscape-scale authorizations for harmful activities may replace project-specific authorizations.This sweeping approach doesn’t lend itself to addressing site-specific or species-specific concerns and consequently presents unwarranted additional risk for species already in peril.

8. Provide for greater implementation of the ESA instead of rewriting the law. According to the Environmental Commissioner of Ontario’s 2017 report, the government “has utterly failed to implement the law effectively.” Challenges should be addressed through improved planning and investment in communications, program development and staffing, not environmental deregulation.

9. Implement many of the more innovative aspects of the ESA including stewardship agreements and ecosystem or multi-species approaches to recovery planning. Putting these tools into practice offers much more promise for species at risk than streamlining approaches to damaging and destroying their habitats.

10. Ontarians have a global responsibility to conserve biodiversity - show us that you are apart of this community of conservation by making the right decisions for species at risk and their habitats. We are now in the throes of the largest mass extinction since the disappearance of the dinosaurs more than 65 million years ago. We must do our utmost to honour our collective responsibility, under the United Nations Convention on Biological Diversity, to maintain and restore the web of life.