The Endangered Species Act…

Numéro du REO

013-4143

Identifiant (ID) du commentaire

23478

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

The Endangered Species Act is designed to first and foremost protect species that are at-risk and that absolutely must remain the sole focus of this act. These are our must vulnerable species and they must be protected no matter what. All species have value, and play an important role in maintaining ecosystems. The loss of one species means the loss of interactions with other species, loss of ecosystem services and the loss of ecosystem functioning. When ecosystem services and ecosystem functioning are lost it ends up costing us in environmental damage and economically as it will cost us more to provide the functions that wildlife provide to us for free. Almost all species are at-risk due to human actions, therefore, it is up to us to protect these species and, not under ANY circumstances remove ANY protections. Rather, these protections should be strengthened, and species should be more rapidly listed, more enforcement of the law is needed, and more funding needs to be provided to protect these species and fund projects designed at studying the best way to protect these species.

Ministers should not be allowed to interfere with listing of a species. This needs to remain a science-based listing project. The requirements for listing a species are already quite detailed and require experts to complete intensive study. This process cannot be undermined by politics. The experts - the scientists and conservationists - know best which species need protecting. Full stop.

Habitat protections are a basic need for species and protections for a species habitat need to be included without delay. A habitat contains all the resources necessary for a species to survive. Without habitat protection you cannot protect a species. So this MUST remain a part of the ESA and habitat protections must be strongly enforced and based on the best available science. This also must be weighed against the costs of inaction - if a species is declining rapidly and threats to the species are large we must protect habitat even if there is some uncertainty about the exact nature of a species habitat. This is a basic step to conserving species and this requirement CANNOT be weakened at all. Ministers should absolutely not be allowed to comment on this aspect. Scientists and conservationists are the experts and would be able to provide the best input in this area.

Nobody should be exempt from protecting endangered species. Under no circumstances should anyone be allowed to obtain a permit to undertake activities that are directly or indirectly harmful to any at-risk species.

Species-specific needs and requirements must still be considered. A broad or landscape approach will not suffice to protect species. Individual species may have distinct needs that cannot be ignored.

Poor implementation of the ESA is the problem, not the law itself. 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.

It is the government's responsibility to protect our most vulnerable species and the residents of Ontario (including myself) will not stand for any weakening to the endangered species act. Work on strengthening and bettering this act for the species it is designed to protect.