I would like to voice my…

I would like to voice my very strong objections to the proposed changes to the Endangered Species Act. After reading the proposal I realized yet again that this government does not value or understand the importance to all of us of the natural world - that we need to protect with legislation natural areas - grasslands , wetlands , forests etc if we expect to keep the biodiversity that is most important to the survival of all .

- “the proposed changes would establish a new Species Conservation Program to support voluntary initiatives like habitat restoration that protect and conserve species”

That voluntary initiatives could take the place of mandated protections is wishful thinking . Without rules and enforcement we know most people will not prioritize species or habitat protection, all they will be concerned with is making money - very few understand or care to educate themselves about the importance of habitat protection and conserving species . The work of community based environmental organizations cannot begin to offset all the damage caused by industry.

- “The government would also have discretion to remove protected species from the list”

There is NO defensible reason why the government should have or need this discretion. This opens the door to further corruption and to making the entire concept of species protection in Ontario nothing more than a farce.

- “Under the proposed new SCA, activities that are harmful to species cannot proceed unless the person carrying out the activity has registered the activity, or in limited situations, obtained a permit. Under the proposed new approach, instead of waiting for the ministry to approve permits, most proponents will be able to begin an activity immediately after registering.”

This approach means a person can simply register an activity that will be harmful to a species, then immediately break ground on said project without any government approvals or public awareness or input. By the time the ministry has had the time to process the registrations the damage will already be done, and you as our government are fully aware of this.

- “Ontario remains committed to species conservation and to promoting activities like habitat restoration, research, and community-based initiatives. This proposal would establish a new Species Conservation Program, which would improve upon and replace the Species at Risk Stewardship Program. Under the new program, the government intends to increase investment in supporting voluntary activities that will assist in the protection and conservation of species by more than four times, up to $20 million per year. The program would also consider a wider breadth of supportable conservation activities.”

This is passing the buck to community groups for drop in the bucket activities instead of holding developers to account and stopping the destructive activity from the get go. It is not on the community to voluntarily struggle to clean up the messes made by ill-considered and explicitly deliberate ignorance on the part of the government and developers. And $20 million is pennies.

The proposed new definition of habitat doesn't include any space for the animals, plants or other species to actually LIVE. Breeding, rearing, staging, wintering, or hibernating are the only activities listed. What about food procurement, and the understood movement and activity patterns of each species?

- “the new registration framework will not include the option to pay a species conservation charge”

What does the new registration framework require " when those conducting certain activities opted to pay a charge rather than completing on-the-ground beneficial actions for certain species."

- “If harm to species occurs, the ministry has tools to enforce the law and hold proponents to account.”

What are they? It is important that these be clearly available for public review.

- “the purpose of the ESA will be updated to drive species protection and conservation while taking into account social and economic considerations, including the need for sustainable economic growth in Ontario”

The very use of the word sustainable here is an affront. It is not sustainable to gut species protections in the name of building subdivisions.”