Thanks in advance for taking…

Thanks in advance for taking the time to read! I have a lot of thoughts on the matter.

If the Committee on the Status of Species at Risk in Ontario (COSSARO), as an independent science-based committee responsible for assessing and classifying species in Ontario, will remain intact, why is the government opting to be able to add and remove species from the list of species at risk? If not COSSARO, who is being consulted, and what scientific research is supporting the option of making a possibly arbitrary choice of species to add and remove. What is stopping the removal of a species that is actively interfering with a development project in the interest of the government? I see that if the government wants to add a species, it needs to match the status given to it by COSSARO, but as this change in the Act is meant to drive development and economic growth, I don't anticipate the addition of species being a primary intention.

On that note... I don't think an Act meant to protect species at risk has any obligation to take into account the economic growth of the province or country. The whole point of having a Species at Risk Act is to protect these species FROM developers who either don't know the impacts or don't care.

The definition of habitat can also not be arbitrarily changed. A habitat is the specific area or environment where an organism (plant or animal) lives and carries out its life processes. This includes breeding grounds (not just at the den/nest), hunting or grazing areas, in addition to the immediate area of a dwelling. This logic would suggest that you can deforest the entire area around a bear den, and still expect the animal to do fine, without its food source, or literally, its habitat. If the desire is to avoid uncertainty, work to research habitat ranges, and create parameters that are easily understood by surveyors and environmental assessors. This change in 'definition' needs to be accompanied by science.

Lastly, having proponents be able to begin an activity immediately after registering rather than waiting for permitting, would open the door to A) developers removing species at risk before surveying or environmental assessments are complete, and B) An increased need for compliance assurance.... which is being done by which group? And how? 'Strengthen our ability' is not exactly a plan.

This just seems like an opportunity to give developers the 'benefit of the doubt' when working with these species, and to trust that they will comply with the regulations in the Act. How will this be enforced? Can we really make a change from permitting to registration if there's not significant moves being made in enforcement as well?

As someone who works in the industry, I'm happy to streamline where it makes sense. Streamlining for developers, and looking to cut corners in the name of economic growth is not compliant with the very essence of the Species at Risk Act, and I openly oppose the proposed changes. If this passes, say goodbye to the plethora of endangered species that make our environment so special.