We are supportive of the…

We are supportive of the proposed amendments to the Endangered Species Act, R.S.O. 2007, as outlined in ERO 019-2636. We agree the Species at Risk Conservation Fund concept will help streamline authorizations and development projects, while also serving to appropriately protect species at risk. It will obviously be critical that costing associated with any impact to an endangered species be reasonable and economically viable for development to occur. We would be very pleased to assist in any further consultation related to costing.

A newly formed Agency to manage coordinated investment would be of benefit to all parties. A strategic large scaled effort would also prove most beneficial to relevant species at risk over the long-term. Given current timelines for development approvals, specially in the City of Toronto, an opportunity to shorten and find efficiencies within this process will certainly be of huge benefit as we continue to cope with the COVID 19 pandemic and associated need for investment in the City and Province.

As it specifically relates to Butternut (Juglans cinerea) we support the concept of paying an economically feasible fee into a fund and working with an Agency to use these funds most efficiently, especially if the result is an accelerated approvals process. We also support the increase in Category 2 Butternut trees which may be impacted from 10 to 15 tress, as well as Category 3 classified trees from 0 to 5. We feel these changes will open opportunity for more meaningful development, while continuing to protect endangered species in alternative and more strategic measures.

Overall, we certainly support the ability to gain greater cost certainty, as well as cost reduction, through the formation of a new Agency mandated to more efficiently allocate funds. By reducing the burden and associated timelines for development projects, it will be possible to streamline investment back much more effectively into our economy.