There are many problems with…

There are many problems with the ESA and it is important that they are addressed and that changes made to it are not just to open "barriers to economic development" without a primary objective of protecting Ontario's biodiversity!

Taking a landscape/ecosystem approach would be an excellent improvement if done with, again, the objective of strengthening the sustainability of Ontario's rich but threatened biodiversity. In the south especially there is much overlap of Species-at-Risk (SAR) and their habitats. The Sydenham River Recovery Strategy is a good example of taking an ecosystem approach to recovery. Unfortunately it was not followed where there were many opportunities, such as in Tall Grass Communities and Carolinian Woodlands, two attempted ecosystem strategies that I was involved in developing but in the end were rejected and only the individual species recovery strategies were accepted. So yes, let's re-examine the value of looking at the whole landscape or a region, and recovery of whole ecosystems again!

There has been much work looking at recovery of landscapes by Carolinian Canada and Ontario Nature; bring those NGOs into the discussion and use their mapping as a guide to protection and restoration of natural landscape linkages. Increasing the forest cover in s. Ontario, especially the highly deforested SW, would go a long way to protecting SAR. Involve Conservation Authorities in targeting restoration plantings in the gaps in the connectivity of the landscape. We also know that increasing forest cover will help protect us against extreme weather events, and climate change is often listed as a threat for SAR.

Further north, the same approach of a landscape level overview could be used to better define important SAR habitats, migration routes, etc. which should be rigorously protected. This approach would be far better than just exempting major industries such as forestry and mining, an anomaly in the spirit of the act that should not continue!

Processes and protection: the species under review are known two or more years before the status is granted (and the backlog of un-reviewed S1 and S2 species is unacceptable!) so provisional lists could be issued, vs. delaying the listing of species given COSEWIC status.

COSEWIC is a group of knowledgeable, and I assume still unpaid volunteer, scientists for each subcommittee. Political interference is unwelcome! There is no need to oversee what the experts are reviewing and the status they give.

It is currently too easy to evade the spirit of the act, such as by allowing the destruction of habitat if another piece of land is set aside as habitat for the SAR. When this was regulated by MNRF, biologists I spoke with have said it is a routine exemption that developers take, but with very little evidence that these pieces of land serve as alternate habitat for displaced SAR.