A very reasonable…

A very reasonable reformation of the ESA! As an environmental consultant, it is currently very difficult assisting clients through the ESA permitting process; a very uncertain process in terms of time and monetary cost. The pay-in-lieu option might provide a much clearer path toward establishing overall benefit. Consolidating funds to a central trust that will coordinate SAR recovery efforts seems like a great idea that I expect will be a more effective and efficient way to promote species recover.

I highly applaud the move toward incorporating considerations of a species' overall range (not just its Ontario range) into COSSARO rankings. I has been troublesome and unnecessary that species that are widespread and common outside of Ontario should receive cumbersome and expensive protections within our province simply because Ontario happens to represent a northern extreme of its range.

While it might be unpopular to some, but I also applaud greater flexibility for the government to temporarily suspend the implementation of protections for newly listed species. It is not always clear how to implement protections for newly listed species and rushed protections can (and sometimes do) result in strong adverse impacts on industry while not necessarily resulting in the desired recovery for the species. Ecology is nuanced and we often do not fully appreciate how much we don't know about a species until is appears on the SAR list. First focus on filling knowledge gaps, then implement smart, efficient and effective protections.

Thank you for this opportunity to comment.