Thank you for the…

Thank you for the opportunity to comment on this proposal. I offer general and specific comments below, based on a 20+ year career in the private sector that includes many species at risk recovery activities but also operating construction companies, educational facilities, etc.

General comments:

Increasing flexibility and removing redundancy is useful, however the focus must always remain on species recovery not economic opportunity or cost.
Ministers are politicians, often with little background in their area of responsibility. Requirements for them to consult with independent experts should not be watered down or eliminated.
The use of the best available science should supplemented, but not supplanted, by other forms of knowledge.

Specific comments:

Section 1A: This may not provide for the needs of a species following assessment if the situation is dire. Extending the time may be a useful option but it should not be automatic and COSSARO (or another independent body) should decide this, not the Minister.
1C: This should not apply in emergency circumstances.
1D: COSSARO uses the best available scientific information. This should only apply if there is scientific information that was not considered or not available during COSSARO’s review. Such information should be independently reviewed by qualified scientists to determine its veracity.
1E: While considering a species’ condition around its broader biologically relevant geographic area, inside and outside Ontario, may be useful for some species, it should not automatically require adjusting classification. Populations on the edge of their range often contain adaptive value that is critical for future survival. Populations may be disjunct and suffer from different threats. Also, Ontarians frequently want to maintain populations of rare species in their province, regardless of any other jurisdiction. The body best able to consider this IS COSSARO. Please revise “COSSARO would be required to adjust” to “COSSARO may adjust”.
1F: Broader membership may be useful, but primary qualifications for the majority of members must still include scientific background.

2: As long as those criteria are not watered down, this may provide useful flexibility. However, similar criteria should apply to requirements or delays to developing habitat regulation.

4. This conservation trust must be carefully developed with sound conservation science for species recovery as the highest priority as opposed to allowing development of sensitive habitat.

4A: No. Politicians must always be required to consult with independent experts.
4B: Only where this does not hinder the recovery of a species at risk (i.e. the current situation with bats).
4C: This may be a useful option, but it should not apply if the activity poses a significant threat to the species or its habitat.

I also offer an additional comment on a regulation under the Endangered Species Act. Under O. Reg. 242/08, section 23.15(1), which defines “educational organization”, this definition is too narrow. Various other organizations such as conservation NGOs and even consultants for short term activities such as stakeholder consultation meetings, provide useful education and should not be precluded from this activity. Please broaden the definition to reflect the modern reality that curatorial institutions are not always owned or operated by government, and that other organizations also have legitimate educational purposes.