One of the most significant…

One of the most significant challenges for site operators, particularly of quarries are large manufacturing sites is the changing requirements. Quarry operators are required to develop site plans decades in advance and may operate anywhere for a few years to several decades. When new species are added they can impact the final or progressive rehabilitation of these sites and lead to additional cost and administrative burdens that were not foreseen. With that in mind, the following is recommended:

- listing of species in an area should be the result of the species being at risk or threatened in the affected area. For example, if a tree species is rare in southern Ontario, but abundant in eastern Ontario, it should not all be listed the same. Similar to fauna as well. Also, if a species is listed at risk on the federal level, it should not automatically be added to the provincial level.

-Species that are listed at risk or threatened due to lack of data should be removed immediately from the list. Care and diligence should be taken for species with minimal populations numbers rather than list individual species as a result of not having enough information.

- the affected species and compensation should be prioritized with a clear objective. For example, creating more habitat for bats, will not necessarily help their resistance to fungus. However, if the goal is to create more roosting habitat, then that should be the compensation when bat habitat is moved. Often, sonar tracking can be required to confirm that bats use a particular area, which is expensive, inefficient and not effective. If the goal is create more bat habitat, then that should be the objective and required under the act. Special permits should not be required.