OFA comments on a proposal under the Endangered Species Act (ESA) to enable the use of the Species at Risk Conservation Fund and to streamline authorizations for certain activities that impact species at risk while maintaining protections for species at risk. OFA acknowledges that actions need to be taken to minimize impacts on species at risk and their habitats, however recovery strategies, government response statements and habitat regulations need to reflect the reality that a single-minded focus on species restoration to the exclusion of all other factors is unsustainable. OFA believes species are endangered and threatened due to urban expansion, not agricultural uses. Prime agricultural land is a shrinking resource; one that must be retained for its ability to produce food, fibre and fuel. OFA believes that any financial costs associated with achieving the goal of preserving endangered wildlife and their habitats should be shouldered by the public, not by the individual farmers and other rural property owners.
The ESA was designed to identify species at risk, protect their habitats and promote stewardship practices that will help protect these plant and animal species and Ontario agriculture is no stranger to this legislation. Six species are being proposed to be eligible under the Species at Risk Conservation Fund, of which four have habitat requirements that intersect with agriculture: Barn Swallow, Bobolink and Eastern Meadowlark, and Eastern Whip-poor-will and Butternut trees. While OFA has no objections to the proposed species listed to be eligible under the Fund, normal farm practices need to be maintained regardless of the presence of a species at risk on land. OFA appreciates this opportunity to provide its perspectives on the proposal under the Endangered Species Act and we trust that our perspectives will be reflected in any forthcoming changes.