Focus area 1, Landscape…

Focus area 1, Landscape approaches: I note the lack of mention of corridors despite the critical importance of those to many species. Any broader approach to the assessment would be invalid without ensuring contiguous corridors rather than isolated areas. Also, the critical areas for the species under consideration must be preserved no matter how much those might be desired by developers or potential country estate or cottage owners.

Focus area 2. Listing process: The "costly impact" to businesses primarily occurs when developers are trying to build on land that should never have been open to development in the first place. With a more measured and careful approach to development permits, that prioritize access to EXISTING public transit, water and sewage lines the situations you describe won't happen.

We need affordable housing not mansions, and shopping and places of employment that can be reached WITHOUT A CAR. Besides, since in almost all cases we don't even know the potential value of the species in terms of future health of our own species, the long term balance of costs cannot be reasonably estimated.

Also, if there is a need for additional review or assessment to improve the scientific basis for a decision, the habitat MUST be fully protected during that time. Sensitive habitats cannot simply be restored; they are often gone forever. For species that have different summer and winter habitats, efforts must be made to preserve both.

Focus area 3: Nine months should be FAR more than enough time for engagement and a statement based on the science available at the time. It can always be amended for new knowledge.

I also see no merit in waiting more than five years for a progress review. Increasing the time might allow the government to do nothing for longer and that's not at all desirable.

I am OK with scientists and only scientists figuring out when to use a general or specific habitat regulation. There should be no business or government representation on any committee that makes such decisions or recommendations.

Focus area 4, Authorization: Conservation agreements are a good approach that could be used more extensively. Overall, this section of the paper reads like a pro-business approach to destroying species at risk because they don't matter. A general fund won't help a species that had only a limited habitat that is now gone. The government can reduce the number of forms to be filled out and the length of time it takes to process them without reducing the protections needed by species at risk.

What seems to be missing is large fines for corporate leaders as well as corporations if they proceed with actions that damage the habitats of species at risk, including barring such corporations from future permits for development in Ontario and from Ontario and municipal government contracts.

General Comments
a) It is critical that other government initiatives such as Bill 66 and plans to increase housing be brought in line with the requirements to protect endangered species. Lately it appears as if the Ontario government is using a multi-pronged approach to destroy critical environmental protections.
And the frequent references to the impact on businesses in this discussion paper strongly reinforce that perception.

b) I wrote my comments before reading the content of the URL I have linked to below, but I fully agree with the comments there.