While I do feel as though…

While I do feel as though commenting is a waste of my Thursday morning as there seems a low chance of the proposed items changing, I still find it is my responsibility as a citizen to provide my opinion.

My first comment revolves around the registration and the start the project change - I feel as though inspection for species at risk should be necessary prior to the start of the project and certification by the government or a third party that is not involved in the proposed development should still be required because as soon as the project begins, that habitat may be damaged and unrecoverable, even of later that development is halted. Also, based on the new habitat definition, it seems as though a destroyed den or other area would no longer be protected, and therefore consequences would be non-existent.

My next comment continues into the new habitat definition. I believe a few crucial pieces as missing, including an expansion to "previously" occupied habitat - protection and conservation should be promoting the ability of species at risk populations to ultimately recover and this is impossible if only the currently occupied habitats are protected. Also, areas in which animals gather/forage/hunt for food should be included, which are often different or a larger area than specified in your "shelter" definition of habitat, but equally crucial for species success.

I do also have a positive comment on the proposal, which is that I do think federally protected species do not need extra provincial paperwork.

I can see why removing "harassment" from the listed of restricted/registered/permitted activities makes sense, however, I think it should be replaced by "distressing" as this encompasses behaviours which should not be allowed, such as poking/prodding or invasive photographing, and is easier to measure, while also having a direct affect on things like reproductive or feeding success. An animal or plant in distress can be directly observed and is less likely to mate or successfully raise babies, or to successfully find food, and we should not be allowed to cause distress to a species at risk animal.

Finally, while I see no reason why the government shouldn't be able to add species to the protected list, I don't think they should be able to remove species at their discretion. I believe this amendment as too high of a chance of being abused by current and/or future legislators, in order to push projects though that would result in species destruction but (indirectly or directly) benefit them. Removing a species from protection should only happen if there is scientific proof of the species no longer needing that protection, and not for any other reason.