FRENCH RIVER DELTA ASSOCIATION
857 Hartley Bay Road
RR 2 Site 10 Comp 4
Alban, Ontario P0M 1A0

January 18, 2013

Krista Adams
Senior Permits & Agreements Specialist
Ministry of Natural Resources, Policy Division
Species at Risk Branch
Permits and Agreements Section
300 Water Street, Floor 2
Peterborough, Ontario
K9J 8M5

Dear Ms. Adams:

Re: EBR Registry Number: 011-7696, Proposed approaches to the implementation of the Endangered Species Act which could include regulatory amendments to authorize activities to occur subject to conditions set out in regulation consistent with MNR’s Modernization of Approvals

The proposed regulatory changes contained in EBR 011-7696 are vague and will not meet MNR’s responsibility to endangered species and their habitat maintenance and protection.
While the ambiguity of this MNR and provincial cabinet’s proposal will serve MNR’s and cabinet’s partners in the mining, energy, forestry, and aggregate industries, it will not meet the primary purpose of the Endangered Species Act which is to protect endangered and threatened species and their habitats required for survival.

It is intriguing to note that the spring 2012 budget proposed amendments to the Endangered Species Act. These proposed exemptions – circumvention of permitting requirements, and removal of deadlines for recovery planning – faced serious public opposition and the budget amendments to the ESA were dropped. To now reposition the budget amendments as regulatory changes, which require only cabinet approval, is irresponsible, misleading and shows the continuing disrespect that cabinet and the MNR have towards the public, and as importantly, endangered species and their habitats. Continue reading →