Smart Prosperity Institute…

Smart Prosperity Institute welcomes the opportunity to provide comments to the Ontario Ministry of the Environment, Conservation and Parks on the Discussion Paper for the 10th Year Review of Ontario's Endangered Species Act (ESA).

Over the past several years Smart Prosperity Institute has undertaken extensive research and convening on policy tools for recovering Canadian species at risk . Although tailored to the federal Species at Risk Act, many of the insights gleaned from this research are applicable to the Ontario statute and context.

The key message of our commentary is that while the Ontario government can significantly improve how it implements endangered species conservation in Ontario, the Ontario Endangered Species Act already contains the tools needed to stabilize and recover Ontario’s endangered species – and so amendments to the legislation are not necessary at this time. Our submission instead focuses on how to use the existing legislation and associated policy instruments to more effectively and efficiently protect endangered species in Ontario, with an emphasis on promoting stewardship on private lands, making better use of multispecies/ecosystem-based management approaches and, in cases where regulatory exemptions are being considered, providing transparent and publicly accessible analysis of the harms to endangered species – and the relevant economic costs and benefits – that would likely accrue through these exemptions. Given that Ontario has a disproportionate responsibility for conserving and recovering species at risk in Canada (many species at risk are concentrated in Ontario), improving implementation of the Ontario ESA is essential.

Although our commentary is based on a selection of issues where we have particular expertise, we share many of the concerns raised in the commentaries submitted by organizations such as the Wildlife Conservation Society Canada – that the Discussion Paper places far too much emphasis on expediting development, and as a result, risks weakening the ESA’s main purpose of conserving and recovering endangered species.

Our submission begins by highlighting what Smart Prosperity Institute considers to be a significant missed opportunity in the Discussion Paper – stewardship on private land – followed by our commentary on specific questions raised in Areas of Focus 1 (Landscape Approach) and 2 (Listing Process and Exemptions Protections for Species at Risk) of the Discussion Paper.