March 5, 2018…

March 5, 2018

Species C partially addresses.

Prior to damaging or destroying safe harbour habitat, a person must submit the notice of activity form, including the name of the target species for which the safe harbour habitat was created or enhanced. OHBA had previously expressed concern that there may be unintended consequences for which there may be some instances when safe harbour habitat provides habitat for non-target species at risk. As such, damage or destruction of safe harbour habitat could have unintended consequences to species at risk beyond the target species. The current regulatory proposal outlines that the Ministry be notified of both target and non-target species at risk when activities are undertaken that damage or destroy safe harbour habitat. In addition, it is proposed that the reporting requirements be updated and clarified to provide additional information on the activity that was carried out to impact the habitat. OHBA is supportive of this proposed amendment and believes that this will alleviate some concerns expressed by potential Safe Harbour proponents and reduce proponent risk from entering into Safe Harbour agreements. OHBA further notes that we had previously expressed concern that the regulatory framework for safe harbour is currently limited to species listed as threatened or endangered. To help enable conservation projects, the MNRF proposes that the regulation be amended so that the safe harbor provisions also apply to special concern species. OHBA is supportive of this regulatory proposal. OHBA appreciates the opportunity to provide comments and advice to MNRF. OHBA continues to recommend that MNRF allow delegated authority rather than the current framework for Safe Harbour Agreements requiring Ministerial approval. OHBA strongly supports a balanced approach to the environmental, social and economic goals of the province to ensure a prosperous and high quality of life for Ontario citizens.

Sincerely

Michael Collins-Williams, RPP, MCIP
Director, Policy
Ontario Home Builders’ Association

[Original Comment ID: 213203]