Please see the attached full…

Please see the attached full submission from the Ontario Home Builders' Association.

To summarize, OHBA is supportive of the government’s commitment to ensuring that the ESA provides stringent protections for species at risk. We are supportive of continuing its work with stakeholders and Indigenous peoples to improve its effectiveness, and modernizing the program based on best practices in other jurisdictions. OHBA supports an approach that increases clarity of requirements, streamlines the process, and implements fair and reasonable response times. 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.

The ESA continues to have several operational and implementation challenges that need to be improved while continuing to provide important species at risk protection. The ESA approvals process should be streamlined for the benefit of both the MECP while also providing greater clarity, consistency, and efficiency to proponents. The MECP should adopt a risk-based standardized approach to approvals based on a prescribed standard set of conditions instead of proceeding through the regular, uncertain, and time-consuming negotiated approvals process. OHBA is supportive of the MECP proposed direction that would enable positive outcomes for SAR while streamlining processes and providing greater clarity for those who need to implement the Act.

OHBA notes that the proposed amendments in the ERO (019-8016) posting will support the More Homes, Built Faster: Ontario’s Housing Supply Action Plan 2022-2023, as they will create smarter and more efficient environmental permissions processes that reduce unnecessary burden to support housing and build critical infrastructure. OHBA is supportive of provincial efforts to improve the effectiveness and implementation of the species at risk program and is generally supportive of the proposals to amend several regulations made under the ESA to increase certainty and streamline processes for Ontarians while also delivering ESA protections where they are needed most. OHBA appreciates the opportunity to provide technical feedback, which is detailed further in the submission.