As an ecologist, this review…

As an ecologist, this review of the Endangered Species Act (ESA) is alarming and littered with no-so-thinly veiled hints that economic growth will be prioritized over conservation. Without even delving into the intrinsic value of our native flora and fauna, Ontario's biodiversity (including its 243 species at risk) provides invaluable ecosystem services that invasive and introduced species cannot replicate. This discussion paper claims that automatic species protections "can contribute to high uncertainty and costly impacts to businesses and the public". I would argue that it is better to err on the side of caution by affording a species more protections that potentially are needed, than to underestimate and risk extirpation. We are currently in the midst of a sixth mass extinction event, caused by humans, that will have major economic and social consequences. More freedom for economic development now will not benefit us in the future when we are facing global shortages of clean water, soil nutrients, crop pollinators, areas of carbon sequestration, etc.
Additionally, it is disturbing to read that proposed changes should "increase efficiencies" for businesses; this runs counter to the ESA's main purpose of protecting species at risk. It cannot be avoided that processes such as those for authorization permits under the ESA will often involve "significant administrative burdens and delays". Destruction, degradation, or fragmentation of habitat has serious ramifications and in the overwhelming majority of cases cannot be reversed. The burden should always be on businesses to avoid and mitigate harm to species and their habitats, rather than modifying the ESA to make it easier for businesses to obtain authorization. The suggestion that businesses could pay into a "conservation fund" instead of fulfilling activity-based requirements ignores the fact that not all habitat is equal. Many populations, including those of migratory species, are dependent on specific areas and may rapidly decline once the amount of available habitat falls below a certain threshold. Destruction of habitat cannot be directly compensated for by contributing to other conservation measures, or even by protecting habitat elsewhere.
I conclude that this discussion paper has presented no evidence to support the claim that the current ESA has harmed the economy, and that based on the goals of the ESA, proposed changes should not "streamline processes" for economic development. The Ontario government should remember the extraordinary value of our biodiversity.