Focus 1: It is said that a…

Focus 1:

It is said that a landscape approach could support proposed activities but there needs to be examples provided of what these might be. This approach also indicates that it may be useful for authorizing activities. It would therefore appear that protections for species at risk may actually be lost.

A landscape approach may be useful for terrestrial species but it would be questionable for aquatic species.

Focus 2:
The public notification process for new species listings could be improved by providing more information and/or news releases about potential listing earlier in the process. COSSARO and the ministry responsible should be “announcing” which species are being considered well in advance so that businesses and the public are aware. Websites need to be updated and kept current. Currently the COSSARO website indicates the next species to be considered are for the next meeting, which is Fall 2018, therefore out of date.

It is said that automatic protection contributes to uncertainty and costly impacts. The provision of “species considerations” well in advance would provide information to inform business decisions. Should these species occur in an area where there is potential “development” then it is a risky venture and should not be considered for future development and this would avoid costly impacts.

Longer transition periods, removing or temporarily delaying protections results in lost protections.

Focus 3:
A general habitat description may be open to interpretation therefore a habitat regulation would provide better protection for species at risk.

Focus 4:
Enabling economic development (under 17 (2)(d)), in areas where species at risk occur will not provide protection for the species. Mechanisms need to be required to offset the harm, loss of species or populations. Repatriations in former ranges should be considered as acceptable offsetting measures.

With respect to the Overall Benefit permit 17(2)(c), we are happy with how this has been working as it contributes to the recovery of species at risk and is not inconsistent with our permitting processes.

We have been working with our counterparts in the MRNF to synchronize our permitting process and our biggest concern with respect to the 10-yr review of the ESA is potential changes that may result in the authorization process that aren't conducive to a coordinated approach. For example, we have been working very closely with the MNRF when issuing permits for Redside Dace projects and we have had comments from proponents on how well it has been working. Ensuring that a coordinated approach can be continued in light of potential changes to the ESA is of paramount importance.

We are happy to meet and discuss these issues further and look forward to continuing our work in the conservation and recovery of aquatic species at risk with our provincial partners under SARA and ESA.