Thank you for this…

Thank you for this opportunity to comment on the 10-year review of the Endangered Species Act (ESA; ERO No. 013-4143). However, I am concerned that the Discussion Paper is a thinly veiled proposal to remove existing protection for the growing number of species at risk in our province and make it easier for industry to continue to degrade and destroy habitat and species-at-risk directly.

Economic development is irrelevant if there is no healthy environment left for Ontarians. The ESA is in place to protect our most vulnerable biodiversity, and is rightly strict. It SHOULD be difficult to get around regulations that are in place for protection. Increasing clarity and transparency is doable through better communications with stakeholders - the Act itself does not need to be changed, other than to be strengthened and to repeal previous exemptions that degrade our environment. Science-based legislation that protects our species is not red tape that needs to be cut - it's necessary to ensure we do not destroy our environment for the sake of short-term economic gains.

The ESA exists to protect and recover species facing extinction in Ontario. Therefore, I support only the direct strengthening of this ESA by:

- Maintaining that every species gets assessed by COSSARO, and if necessary receives a science-based Recovery or Management Strategy, a Government Response Statement and a Progress Report within existing mandated timelines. Any "landscape approach" must exist over and above species-specific regulations.

- Maintaining science-based listing by COSSARO, and abandoning the idea of allowing ministerial discretion regarding habitat and species protection under section 9 and section 10 of the ESA

- Preventing any appeal process to COSSARO assessments and subsequent listing on SARO

- Requiring all proponents of harmful activities to provide an on-the-ground, monitored and enforced overall benefit to impacted species and abandoning your proposal to create an option for such proponents to pay into a conservation fund to compensate for conducting activities that are harmful to species at risk

I ask that you commit to actual strengthening the ESA by:

- Repealing the exemptions created in 2013 to permit forestry, hydro and mining industries to conduct harmful activities to species at risk

- Repealing the exemption created in 2016 to allow hunting and trapping of the Threatened Algonquin wolf

- Amending section 57 (1)1 of the ESA so that exemptions will only be allowed if they do not jeopardize the survival and/or recovery of Endangered and Threatened species

- Affording section 9 and section 10 protection to any species that has been assessed as Special Concern in two consecutive assessments by COSSARO until such a time when the species' assessment results in downlisting to Not At Risk

Economic development can be achieved in a sustainable way that benefits all stakeholders without sacrificing our endangered species and vulnerable habitats. Once they are gone, they are gone forever. That is an unacceptable outcome when we have the power to prevent it from happening, if only we choose to value a holistic approach that does not provide a free pass to development and ongoing urban sprawl. We are better than this. Let's prove it by protecting our species rather than constantly trying to put a price tag on them.