ESA should adopt a landscape…

ESA should adopt a landscape approach that recognizes the characteristics of the Northern Ontario with its large expanses of natural areas, limited development pressure and different ecological dynamics than Southern Ontario.

ESA authorization process should recognize that the City of Greater Sudbury has been creating habitat since 1978 through its Regreening Program, which has benefitted some species at risk.

ESA authorization process should offer greater flexibility, such as conservation banking, conservation easements, contributions to the management of large natural areas and contributions to the City of Greater Sudbury's unique habitat creation method for certain species at risk through its Regreening Program.

Automatic species and habitat protections may not be appropriate where habitat is not likely a limiting factor.