I am strongly opposed to the…

I am strongly opposed to the proposal. This is not at all a balanced approach. While I understand current priorities to build the Ontario economy, this cannot be done at the expense of the environment or species at risk. Greater time and consideration should be given in order to review the evidence and prepare a proposal that continues to protect species at risk, and even improves existing protections. I do not believe that protecting species at risk and growing the economy are two mutually exclusive concepts, as this proposal seems to suggest. Please see more detailed thoughts on this proposal below.

COSSARO:
- The government should only have the power to add species to the list of protected species. While the government is chock full of experts who have multiple degrees and a passion for species conservation, it is ultimately the Premiers Officer who gives direction and employees must follow. Sound advice is repackaged and watered down, and this government should not be allowed to make decisions on what species are removed from the list. Only COSSARO should be able to make the decision to remove. I do not trust this government to do what is right. I have every belief that this government will turn down sage advice from their own employees to delist a species if it suits their agenda. Additionally, any changes to the list of species at risk should be fully transparent and published online before coming into effect for public comment.

Removing "Harass" and changing the definition of “habitat”:
- The term “Harass” should absolutely remain in the ESA, and if for whatever reason the Species Conservation Act goes through, the term should remain part of the legislation. Removing the term "harass" from legislation opens the door to enable human activity that would likely result in the overall decline of species at risk populations, because their energy is spent trying to avoid the harassment. They will reproduce less (which is in contradiction with the goal for species recovery); have overall poor body conditions and die prematurely; or try to migrate away from the area, which will cause them to die because there is no where suitable to go.
Additionally, the term "habitat" should absolutely not be changed to remove a species range. The literature is plentiful on species habitat requirements to thrive, on what a species needs to recover. To whittle the definition of habitat down to "a den, nest, occupied or habitually by one or more members of a species for the purposes of breeding, rearing, staging, wintering, or hibernating" is further evidence that this government has no desire to protect species at all. Species habitat requirements as a whole should conitnue to be considered under legislation. Without protecting a species entire habitat, meaning the range in which they need to survive beyond where they den or nest, considering the other ecological factors required for survival, is neglectful. The ESA's definition is already lacking, yet this government proposes to further reduce it, rendering it entirely ineffective for the benefit of large corporations.

Duplication with Federal Legislation:
- I understand the need to remove duplication, however, the government needs to ensure that measures are taken to ensure protection for aquatic species and migratory birds. Additionally, protections should be included in provincial legislation in the event of changes to federal legislation, so that protection is continued in Ontario.

Recovery Plans and Documents:
- The government should be required to continue developing recovery strategies and management plans, government response statements, and review of progress. As the largest land owner in the province, the government has a responsibility to ensure we are headed in the right direction for species recovery, not relegate their role to guidance documents to give Ontario land to large corporations and rich donors. As an entity that provides some funding to species recovery and habitat restoration, the province should be responsible for determining recovery progress.

New Species Conservation Program/Winding down the SCAA:
- The government should commit to spending over $20 million per year on projects on top of what has been collected to date by the SCAA. There should be a timeframe by which the government is required to spend these SCAA funds on conservation projects.

Advisory committees:
- Do not agree. The SAR Advisory Committee should continue.

Updated Compliance and Enforcement:
- Additional tools for enforcement are welcome, however won't be effective without more Conservation Officers to use them. To have an impact there needs to be more conservation officers to respond and investigate violations.

Registration First Approach:
- Strongly oppose this change. Permits and authorizations were included in the ESA for a reason, and using a registration first approach, allowing individuals to start projects without any review or oversight, is neglectful of the government. This will result in local extirpation of sensitive species, and ultimately benefits developers only. This is blatant disregard by the government for the responsibility they have in species protection and recovery. There are not enough Conservation Officers to check in to make sure a project that has started is following rules in regulation, regardless of what compliance and enforcement tools are added. Projects should continue being required to have government authorization prior to beginning any projects that may adversely impact species at risk.

Impact on human health:
- Finally, species diversity is critical to ecosystem health, and therefore is critical to human health. I am concerned that the government’s prioritization of development over protection of species at risk and the environment will have adverse health outcomes for the people of Ontario. Therefore, the government should have a vested interest in protecting all species in our province.