Thank you for the…

Thank you for the opportunity to comment on this proposal.

I would like to start this response by providing a bit of background on my involvement with the provisions of the ESA. I am currently an environmental consultant who is employed by an engineering firm. My experiences with the ESA, and its various provisions, authorizations etc. primarily fall into the following sectors:

• Private development
• Infrastructure development
• First nations
• Research and policy development

I am currently a certified butternut health assessor and have practical experience with a wide range of Endangered and Threatened species currently protected during the ten years the ESA has been in effect, by the provisions of the ESA in Ontario including: Blanding’s Turtle, Butternut, Least Bittern, Henslow’s Sparrow, Hill’s Thistle, Kirtland’s Warbler, Pugnose Shiner, Wood Turtle, American Eel, Lake Sturgeon (Great Lakes – Upper St. Lawrence Population), Redside Dace, Silver Shiner, Bank Swallow, Barn Swallow, Bobolink, Eastern Meadowlark, Eastern Whip-poor-will, Little Brown Myotis, Eastern Small-footed Myotis, Eastern Foxsnake (Georgian Bay population), Eastern Hog-nosed Snake, Gray Ratsnake (Frontenac Axis Population), Tri-colored Bat. In addition to this list of species, I have also been involved in projects which involved species of Special Concern (including species previously listed as endangered or threatened but which have been down listed over time).

I am also certified in several disciplines which involve or overlap the provisions of the ESA in some aspects, such as wetland evaluating, fisheries assessment (MTO/DFO/MNRF protocol) and ecological land classification, and have experience with regards to the overlap with Federal SARA legislation, preparation of policy and management documents. I have engaged with MNRF at the district level (biologist, planners), at the policy level (head office policy) and Conservation officers from an enforcement perspective.

I offer this information to support some specific examples of where I have seen the provisions of the ESA work well, or not so well and to emphasis that while I may be experienced with certain species or taxa (i.e. expert with some species or certain types of projects), I am not an expert on all of Ontario’s Endangered or Threatened species and I hope this information provides better context for the comments, examples and recommendations provided below sections outlined in the 10th year review of Ontario's Endangered Species Act: Discussion Paper.

1. Landscape Approaches;
2. Listing Process and Protections for Species at Risk;
3. Species Recovery Policies and Habitat Regulations, and
4. Authorization Processes

The comments provided in the accompanying pdf. document (included in this format due to the wide scope of this ERB posting) are founded on experiences in the past 10 years as it relates to my own personal interaction with the ESA, its regulations and authorizations within the landscape of Ontario. These comments are based on my position as a professional biologist, a naturalist and citizen of Ontario with a vested interest not only in the protection of SAR and their habitat but also in the continued economic development and growth of the Ontario economy in particular as it relates to development, transportation infrastructure, resource management (forestry, aggregates, mining). Given the purpose of the Endangered Species Act, it is my opinion that a moderated approach to revisions, deletions or general changes to the act, the regulations or the permitting and approval process (authorizations and regulatory exemptions) is the most responsible approach to balancing needs of Ontarian's and needs of species considered to be at risk. While the immediate benefit to many species may not be apparent at this time in terms of economic factors, all SAR represent natural resources which should be responsibly managed by government, organizations, corporations and private citizens within our province.

Thank you for considering my comment