I am commenting as a Master…

I am commenting as a Master of Environmental Science candidate from the University of Toronto, Scarborough.

The government stated in the discussion paper for this review of the ESA that "the act has been criticized for being ineffective in its aim to protect and recover species at risk, for being unclear, administratively burdensome, time consuming and costly for applicants, and for creating barriers to economic development." I agree that the ESA has not been sufficiently effective in recovering species at risk - however, improvements need to be in the direction opposite of the one I fear the government is taking. For example, Section 17(2)(d) states that "a significant social or economic benefit permit may be issued for an activity that will result in a significant social or economic benefit to Ontario, but the activity would have impacts that are otherwise prohibited under the Act." I am concerned that the Ford government will make use of this loophole to keep pushing through development projects that fragment and/or destroy crucial species at risk habitat, under the guise of "economic benefit". At some point, there is no economic benefit that outweighs the value of Ontario's biodiversity and ecological integrity.

There are 243 species at risk in the province, including many reptiles and amphibians and one of Canada's most iconic large mammals, the Boreal caribou. With climate change on track to worsen and make many species more vulnerable to decline, we need bold action now, not weak legislation that capitulates to business interests. Ontario's economy is strong and I see little evidence that our already-ineffective ESA constitutes a significant burden to business. And if the government is serious about protecting our wildlife, that means it will often have to say "no" to development projects and business practices that cause harm to wildlife and habitat.

Our species at risk are far too important to be de-prioritized in favour of business and development interests. I hope the government will close loopholes in the ESA, raise the standard for exemptions and enhance enforcement of compliance.

Thank you.