Detailed habitat guidance…

Detailed habitat guidance for all listed species is ideal. Detailed guidance would be especially helpful for those species with large home ranges who are generalists - for example turtles and snakes. It would be very helpful moving forward to have very clear metrics which allow anyone to discern what is protected habitat, and what is not. The process/procedure/guidelines/policy should be objective, science-based and easy to understand and apply on a landscape.

It makes sense to have regional approaches similar to significant wildlife habitat and criteria for significance based on ecoregion for example. Geography matters; Ontario is a large and diverse province with very different habitats depending on where a project is located.

Blanding's turtles are much less 'at risk' in central and Northern Ontario compared to their counterparts that still persist in southern Ontario e.g. Rouge River population. Practical approaches to species protection, and achieving a balance between environment, social and economic considerations should not just be 'lip-service', these should be tangible and demonstrated when proponents undertake 'registerable' activities.

More than anything, it's my experience that clear and consistent guidance and messaging needs to be available. If Ministry staff have any role in interpreting or implementing that guidance, they should receive Ministry-wide training (at the outset and ongoing) so that the answer a project proponent gets in Red Lake is consistent with the answer they get in Kingston or Toronto when one is considering the same species. Fisheries and Oceans (DFO) have a process for Fisheries Protection (Request for Review) that is predictable and well-implemented. It is clear to both consultants and project proponents when a review is needed and when an authorization may be required. The implementation of the SCA is an opportunity to foster stewardship and species protection while balancing a reasonable approach to development activities.

Lastly, it would be helpful for municipalities to have access to resources or templated materials so they can ensure consistency with the PPS. This would be useful for both their own projects, and projects they approve within their boundaries.

thanks for the opportunity to comment.