Question: In what…

Question: In what circumstances would a more strategic approach support a proposed activity while also ensuring or improving outcomes for species at risk? (e.g., by using a landscape approach instead of a case-by-case approach, which tends to be species and/or site-specific.)

- Species-specific policies and landscape approaches should not necessarily be regarded as an “either or” situation. These could be considered together as an integrated approach, which may be especially useful for migratory species or those with a large individual range.

Question: What changes would improve the notification process of a new species being listed on the Species at Risk in Ontario List? (e.g.,longer timelines before a species is listed.)

- A lengthy public notice about new listings of Species at Risk can produce problems of its own. When announced well in advance, these notices can instigate a “last minute opportunity” mentality for unscrupulous hunters, fishermen, developers or others who may not respect environmental ethics. In this regard, longer timelines for advanced notice are not a feasible solution.

Question: Should there be a different approach or alternative to automatic species and habitat protections? (e.g., longer transition periods or ministerial discretion on whether to apply, remove or temporarily delay protections for a threatened or endangered species, or its habitat.)

- The option of allowing ministerial discretion to “to apply, remove or temporarily delay protections for a threatened or endangered species, or its habitat” would inevitably leave the Ministry at odds with its own SARPAC and risk compromising its own mandate to protect Species at Risk. The Ministry would further risk the public perception of pandering to private interests.

Question: In what circumstances would a different approach to automatic species and habitat protections be appropriate? (e.g., there is significant intersection between a species or its habitat and human activities, complexity in addressing species threats, or where a species’ habitat is not limiting.)
- There are no ethically sound alternatives to automatic species and habitat protection.

Question: How can the process regarding assessment and classification of a species by the Committee on the Status of Species at Risk in Ontario be improved? (e.g., request an additional review and assessment in cases where there is emerging science or conflicting information.)

- Anyone with basic knowledge of habitat and Species at Risk would likely regard this question as manipulative and self-serving, designed to pander to private interests. Situations of “emerging science or conflicting information” are something that are best left to the professional discernment and shared consensus of the Committee on the Status of Species at Risk in Ontario. In terms of accountability, having the names of those serving on this committee and their meeting minutes available to the public upon request could address this matter. Otherwise, additional reviews and assessments would not be recommended, since they would only serve as a delay tactic for those with opposing views, thereby denying timely protection to key species.

Question: In some cases, the time limit of nine months to develop the Government Response Statement for an endangered or threatened species is too short, and there is no option under the Act to extend this timeline when needed. In what circumstances would a species and/or Ontarians benefit from additional time for the development of the Government Response Statement?

- Requests for additional time to develop the Government Response Statement could be accommodated in the Act, but only with respect to the Committee on the Status of Species at Risk in Ontario (COSSARO) or the Species at Risk Program Advisory Committee (SARPAC). Requests for extensions from any other committee or government body would be regarded as self-serving, foot-dragging or pandering to private interests.

Question: In many cases, conducting a review of progress towards the protection and recovery of a species within five years of the Government Response Statement is too soon. In what circumstances would a longer timeline improve the merit and relevance of conducting a review of progress towards protection and recovery?
- Much like my response to the previous question, requests to conduct a review of progress beyond the standard 5 year period could conceivably be afforded a two year extension (essentially 7 years in total), but only at the request of the Committee on the Status of Species at Risk in Ontario (COSSARO) or the Species at Risk Program Advisory Committee (SARPAC).

Question: The development of a habitat regulation is not needed for each species that is endangered and threatened since general habitat protection applies and can be clarified through the use of general habitat descriptions. In what circumstances is the development of a habitat regulation warranted, or not warranted?

- This appears to be another question skewed in favour of private interests. If this statement were actually true and general habitat protection for a species could indeed be clarified through the use of general habitat descriptions, then how did that species become at Risk in the first place? Regardless of whatever habitat regulations that are or are not developed for a species at risk, they should be developed by the Species at Risk Program Advisory Committee (SARPAC).

Question: What changes to authorization requirements would better enable economic development while providing positive outcomes and protections for species at risk? (e.g., simplify the requirements for a permit under s. 17(2)d, and exemptions set out by regulation.)

There are no changes to authorization requirements would better enable economic development while providing positive outcomes and protections for species at risk. Stop this nonsense of framing a narrative that inevitably serves private interests at the expense of our Species at Risk. If investment is important, then invest in your own government and stop the budget cuts to the ministries that regulate and enforce these laws.