I disagree with just about…

I disagree with just about everything in these proposed changes.
- Science-based listing of species at risk nd automatic protection of listed species and
their habitats provide certainty, whereas ministerial discretion politicizes the process, inviting delay and controversy.
- There should be no change to the ESA regarding the listing process and the role of COSSARO. The law
sets out a transparent approach to listing based on a consideration of “the best available scientific
information, including information obtained from community knowledge and aboriginal traditional
knowledge.”
- Edge of range species should not be denied protection based on their status outside Ontario. This will just promote extirpation and extinction within our own province.
- There should be no alternative to automatically protecting threatened or endangered species and
their habitats upon listing. Allowing the Minister to remove or delay protections is inappropriate and invites political meddling.
- Legislated timelines are intended to ensure that actions needed to recover species occur without
undue delay. There should be no change to the legal requirement to produce GRS within nine months
of the release of Recovery Strategies or Management Plans. Failure to meet the legislated deadlines
is a chronic problem, which should be addressed through improved implementation, not weakening
of the law.
- There are already sufficient tools for authorizing harmful activities. No new tools are needed.
Challenges should be addressed through improved implementation.
- Do not remove the requirement to obtain Cabinet approval or to consult with an independent expert
regarding sec. 17(2)d permits. These are intended to be available only for projects that “result in a
significant social or economic benefit to Ontario” and that will not “jeopardize the survival or recovery
of the species in Ontario.” These are appropriate requirements and ensure that such permits are
issued only an exceptional basis.
- Do not remove the requirement for the Minister to seek an independent opinion on regulations that
might jeopardize the survival of a species in Ontario. That would only make it easier for harmful
activities to proceed, without proper scrutiny.
- "To allow proponents of harmful activities to pay into a fund in lieu of fulfilling on-the-ground
requirements that would otherwise be imposed under the ESA." This is the worst idea. This is the Endangered Species Act, not the Endangered Business Act. The priority must be on protecting and recovering species at risk. We cannot put development interests ahead of the health of our ecosystem. Allowing violators to pay a fee is not a deterrent. Proponents of harmful activities should NOT be allowed to simply pay into a fund rather than providing on-the-ground reparation for damage done. This easy way out reduces accountability and facilitates harm to species at risk and their habitats. Retain the current requirements to provide an on-the-ground, overall benefit to species harmed.

The ESA (sec. 18) provides a means to harmonize its requirements with other legislative or regulatory
frameworks, based on the standard of providing an overall benefit to species negatively impacted.
Unless this standard is maintained, species will continue to decline.