Comment
Focus 1 - Landscape Approaches:
Landscape approaches could help when there are multiple species within the same area that are endangered. It's usually better to deal with those cases as an interconnected problem. The rest should still be species-specific because general guidelines and one-size-fits-all never works.
Focus 2 - Listing Processes and Protections for SARs
The government should post notices on all social media platforms to reach a wider audience. There should not be a longer wait-time, nor should there be a change to automatic listing. The faster species are listed as protected, the better the chance of them rebounding. There should also be no ministerial discretion, that defeats the purpose of doing an assessment to determine which species should be listed. It also opens the door to lobbying and political pressure.
Focus 3 - Species Recovery Policies and Habitat Regulations
There should be an ability to extend the timeline for developing a Government Response Statement when an appropriate plan cannot be created in time. It's better to take more time to create an adequate Statement than to rush and create a subpar one.
Habitat Regulations should always be created, but should have a clear scope.
Focus 4 - Authorization Process
The authorization process should not be streamlined unless there is a guarantee that nothing will be left out. Applicants filing multiple applications should still do multiple applications.
Activity-based requirements are more proactive than paying into a conservation fund, but conservation banking could be a viable option. A combination of less-stringent activity-based requirements and also participating in conservation banking would be useful. Since organizational activities are often permissible for unavoidable impacts if mitigation measures are in place, they should still have to do everything in their power to mitigate their own impacts via activity-specific requirements.
Proponents that are being regulated by other legislation along with the SAR regulations should not have a streamlined process. The needed of species at risk will not be adequately met if they are combined with other regulations.
I also support CFW's position, except where it contradicts mine as mentioned above.
Supporting links
Submitted March 2, 2019 2:30 PM
Comment on
10th Year Review of Ontario’s Endangered Species Act: Discussion Paper
ERO number
013-4143
Comment ID
23085
Commenting on behalf of
Comment status