1. Landscape level…

1. Landscape level approaches are already possible under the ESA. It is important that SAR protections are species-specific and site-specific otherwise the needs of species that occupy very small amounts of habitat or have very specific habitat requirements may be left out. In addition, simply having habitat available is not always enough to make a species able to use that habitat, therefore habitat where the species is known to already exist must be protected for some species. If new tools for landscape approaches are created then great, but they should NOT replace species specific or site specific tools.

2. There is absolutely no need to lengthen the process for listing a species; it can already take several years during which time the species may decline further. Secondly, automatic protection for the species and it's habitat is critical otherwise what's the point in having an ESA to begin with? Thirdly, additional review of COSSARO reports seems redundant as COSSARO is already made up of experts and their reports are based on available science. This seems to be an attempt to undermine science, which again would make the ESA pointless.

3. The time limits of nine months for a government response statement and five years for a review of progress is appropriate. Rather than extending the deadline, the government should commit the necessary resources to meet it. If data is available over a longer time period or stewardship actions will take place over a longer timeframe then simply state that in the progress report.

4. As pointed out in the government's discussion paper, there are already numerous provisions under the ESA to allow activities that would otherwise be prohibited. Therefore new authorization tools seem redundant, especially as the ministry always approves permit applications. Rather than creating new ways to get around the ESA, the government should be tightening existing protections by, for example, repealing the broad exemptions given to several industries including the forestry industry. Enforcement of the ESA has been extremely weak and the government should also commit to providing the necessary tools and resources for compliance monitoring and enforcement.

The discussion paper implies that of Ontario's 30,000 species, all are thriving except for a small number. In reality, current research suggests that somewhere around 50% of species are declining (Living Planet Report Canada, 2017). In the decade since the ESA has come into force there are very few success stories and more and more species are becoming at risk. However, the discussion paper suggests that we should be making it easier for business to destroy species at risk and habitat. Weakening the ESA will not help to achieve "positive outcomes for species at risk." As others have pointed out, this is not the Endangered Business Act but rather the Endangered Species Act.