The proposed changes to the…

The proposed changes to the ESA are shortsighted and put short-term economic gain over the ability for our natural ecosystems to sustain species at risk and ourselves. Protection of individual SAR and their habitat has broader societal benefits including carbon sequestration, water quality protection, and greater biodiversity benefits. These are essential for sustaining human life. Narrowing the scope of the ESA puts these benefits at risk, posing threats to future generations of Ontarian's benefiting from healthy natural ecosystems.

My particular concerns with this proposal are:
- Species Classification & Listing - the classification of species should remain independent and science-based. The government should not have discretion to remove protected species from the list. What purpose does an independent science-based process provide if the government can choose to add or remove species based for convenience? On what criteria or guidelines would government discretion allow removal from the list? This is extremely concerning.

-Changes to the definition of 'habitat' - narrowing the definition of habitat to exclude areas necessary for providing food for SAR is misguided. A dwelling place and the immediate surrounding area is not sufficient to support species that are already in decline or at risk. Food sources remain an essential part of the habitat required for a species to thrive. SAR will not survive with their dwellings alone.

-Registration-first approach - the new registration system proposes that proponents will be able to get projects started as soon as they have completed their online registration, eliminating the step of waiting for the ministry to review and approve permits. What backstops are in place for developers who harm species at risk or their habitat due to lack of understanding of their property? This is setting up the province to be reactive to cases where destruction of habitat has already occurred. Our shared environment does not rebound in quick timescales. Damage is challenging to undo, particularly when Species at Risk are involved. Recreating nature is expensive & regeneration and return of species can be slow. Protection of limited existing habitats is essential to maintain species populations if we ever hope to see their populations increase. Taking this approach to expedite the development and permitting process will come at a huge environmental cost, that is irresponsible. Alternatives to expedite the development and permitting process include additional capacity and internal efficiencies to move proponents through the review and approvals process more quickly.