Hello, and thank you for the…

Hello, and thank you for the opportunity to comment.

As a consulting ecologist dealing with the ESA directly since 2012, I am generally not in favour of additional relaxation of regulations, as I find the Act itself has been increasingly ineffective at protecting species. Enforcement has been so lacking that it has been advantageous for those with ESA conflicts on their properties or worksites to practice the approach of "shoot shovel shut up" with regard to ESA issues, and most of the time this is very effective. Fines have been so minor as to generally be a nuisance or can be incorporated into the 'cost of doing business' so pose no real concern for those convicted.

The proposed changes to the Redside Dace protections will result in additional impacts to downstream water resources, as well as make recolonization of former habitat nearly impossible. However, I would consider de-listing of historic habitat reasonable if habitat changes have been so severe (e.g. armouring) as to make recolonization effectively impossible/highly unlikely.

Regarding Butternut, I would suggest that Butternut impacts and registration could proceed immediately once the results of approved genetic testing on the individuals to be impacted were submitted to the MECP, along with the Butternut Health Expert Report(s). This will ensure that no native specimens with anomalous traits or that were assessed poorly/out of season will be impacted without due compensation.

Lastly, if the government is truly interested in reducing the wait times for permits under this Act, HIRE MORE STAFF! I have had the pleasure of interacting with MNR/MNRF/MECP SAR biologists for many years. They have been, by and large, professional, pragmatic and helpful to the best of their abilities and resources. If you had more of them, then processing would be much faster and I am sure the overall provincial savings in lost time and project revenue would more than make up for their wages. Developers can handle costs as long as they budget for them. They cannot budget for long and unclear waiting times for responses, while survey seasons come and go, forcing them to wait for the next season for their consulting teams to collect whatever information they forgot to collect in the first place. You may also want to consider modifying the Act so that businesses and/or professionals who do NOT report a SAR protected under the Act, or who advise a client to act to the detriment of known or suspect individuals and/or habitat of SAR, be subject to prosecution under the Act. I am certain this would improve the caliber of material that was submitted to MECP for their review, again, streamlining the process with no ill impacts to SAR.