As an ecologist working in…

As an ecologist working in Ontario's environmental sector, and as an Ontarian who deeply appreciates the incredible wildlife and plant life that call this province home, I am extremely concerned about many of the components of this proposal. Some aspects I and many others would appreciate clarification on:

1. What justification will allow the government to remove a species from the list of protected species? How will this be determined by officials? And why would the reasoning for a species to warrant protection, provided by COSSARO, be discredited?

2. While I support providing more defined guidelines on what constitute habitat for proponents to fully understand what parts of the landscape they need to be protecting are, I am deeply worried about the redefinition in this proposal. Core animal habitat goes beyond simply where they live and the immediate surrounding area. This simply promotes habitat fragmentation, which harms biodiversity, population genetics, and ecosystem connectivity. What about turtles that may utilize different locations for wintering vs. nesting, and the land they traverse in between? How can we suggest that only a small pocket of an animal's range is sufficient for their protection and survival? Furthermore, of "core" activities, FORAGING is notably absent. All's well if we protect a prothonotary warbler's nesting area, but what happens when they go out searching for food to support their young and lack the habitat to do so?

3. Transitioning from permitting to registration - who will be following up with these proponents and their projects to ensure that regulations are being followed? A lack of formal review/oversight on new development is VERY concerning to me. Will these projects simply be going unchecked? Who and what will be holding proponents accountable here?

Thank you for your consideration. I sincerely hope the Ministry takes these and other concerns of the public seriously, and adjust this proposal accordingly.