I disagree overall with this…

I disagree overall with this interim proposal intended to repeal the Endangered Species Act and replace it with the Species Conservation Act. I ask that the Ontario Government does not go forward with this proposal for the following reasons:

1. The proposal and Bill 5 will result in removing key safe guards for Species at Risk that are currently part of the Ontario Species at Risk Act. The key safe guards that are proposed to be removed, include:

- Abandoning Ontario's commitment to protecting species and ensuring their recovery by replacing the strict criteria for habitat protection with a discretionary regime i.e. the proposal would offer very limited protection to only a very small fraction of the habitat of species where they need to survive and recover in accordance with any Government Statements or related Species Recovery Plans. For example, the Bill would narrow the definition of "habitat" for animals to exclude areas outside of dwelling places and the immediate area around it. An example of this includes the critical habitat of Blanding's Turtle in those terrestrial habitats where they travel up to several kilometres between summer habitat and nesting sites or overwintering habitat.

2. The new legislation would also eliminate provincial protection for federally listed migratory birds and aquatic species — many of which are not adequately protected under Federal legislation, leaving significant gaps.

3. The Act would replace the science-based listing and permitting process, and give the government broad discretion to refuse to protect species and their habitats.

4. The Ontario government is using the trade war as cover for its war on species. The only thing that has been ‘unleashed’ with this bill is an irrational vendetta against vulnerable ecosystems, plants, and animals.

5. This legislation would also erode the consultation rights of Indigenous people, by eliminating permits over a wide range of destructive activities. It also risks setting a dangerous precedent for bypassing meaningful Indigenous consultation, contravening constitutional obligations and the principles of reconciliation.

6. The proposal adopts a “register-first, ask-questions-later” model for species-at-risk permits, allowing developers to proceed before environmental implications are fully known.

As an Ontario citizen I demand that the above concerns be addressed before a decision is made regarding this ER Proposal.