Thank you for the…

Thank you for the opportunity to review the ESA (2007).

When this act was created it was internationally renowned for having a standard of each project that impacts SAR must achieve an overall benefit to the impacted species. The act held this standard while providing the flexibility to allow economically important projects to proceed, even in SAR habitat, so long as the impact is offset elsewhere.

However, in 2013 exemptions were created to reduce this impressive, yet balanced approach. Several industries were given blanket exemptions from the overall benefit standard. These changes were shameful and pandered to the few rich folks. The same few rich folks the Ford government appears to be pandering to now. Let us hope this is not the case.

As a first step, the Ford government should repeal the 2013 exemptions that reduce the stand from "overall benefit" to "mitigating adverse effects".

Here are some things that are very important to retain as they are crucial to the protection of SAR:

1) The species at risk stewardship fund should be retained and the government should increase the amount it contributes to this fund each year. Furthermore, this fund should put a higher priority on projects that conduct research to improve our understanding of effective mitigation and offsetting measures.
2) the species at risk research fund of Ontario should be retained and its support increased.
3) The number of enforcement officers should be drastically increased as they simply do not have enough to do their jobs effectively.
4) COSSARO should continue to be an independent, scientific panel that does not consider socioeconomics when determining the status of a species.

Here are some things that should change:
1) Permitting under the ESA, the FWCA, and the PPS should be integrated. The redundancies in applying for multiple provincial permits cost developers time and money. Each permit has its own set of timelines and its own independent government reviewers.)
2) A tracking system of whether or not a project achieves the overall benefit at some time (e.g. 5 years post completion) should be implemented and corrective actions taken should the project fail.

Thank you for this opportunity to comment and make the ESA a stronger and more effective at recovering species at risk.