Area of Focus 1: Landscape…

Area of Focus 1: Landscape Approaches
1. Move forward with a permanent section 55(1)(b) regulatory exemption to the forest sector to continue enabling landscape approaches currently being delivered under the Crown Forest Sustainability Act (CFSA).
2. Working under the section 55 (1)(b) regulation, the Ministry of Natural Resources and Forestry (MNRF) must develop workable species at risk policy delivered under the CFSA that contributes to working landscapes and functioning ecosystems while incorporating socio-economic impact analysis, jointly, with practitioners, affected stakeholders, and Indigenous communities.

Area of Focus 2: Listing Process and Protections for Species at Risk
3. Overhaul the membership of COSSARO to reflect more generalist professionals and Indigenous communities rather than academics with expertise in a very limited field of study. Known experts in a particular species, including local MNRF biologists and local RPFs should be invited to participate in the deliberation of species being evaluated by COSSARO at least 12 months before the committee meets to evaluate the species’ status.
4. Develop a clear process for using the “data deficient” category, particularly for species with a wide distribution and lack of data.
5. COSSARO should consider the use of regional sub-populations to account for differences in status across the province, risk to the species and the relative risk of human activities. Populations of species at the normal edge of their ranges in Ontario, outside of their core range, should be evaluated with due consideration of their global population.
6. Add an additional layer of accountability by having the responsible minister weigh scientific evidence provided by COSSARO with the socio-economic impacts before a species is automatically listed and protected.
7. Reassessment of species at risk should be considered when credible evidence has been presented to the responsible ministry beyond what is currently permitted within the ESA.
8. Enable individuals and organizations to report on SAR sightings without the perceived or real fear of being penalized for doing so.

Area of Focus 3: Species Recovery Policies and Habitat Regulations
9. The current 5-year review should go beyond simply listing actions that have taken place. A biological review of the species should be included and feedback into the COSSARO listing process.
10. Habitat renewal should not be considered habitat destruction.

Area of Focus 4: Authorization Processes
11. Remove the July 1st, 2020 expiry found in O. Reg. 242/08 (22.1) to forest operations on Crown land giving the sector and government greater certainty.
12. Replace the term “overall benefit” within sections 17(2)(c), 18(1)(e)(iii)(A), and 18(2)(f)(iii)(A) with “positive outcomes” to species at risk.
13. Equivalency through section 55, not harmonization through section 18 is required for future success and is well supported by legal precedent.