Overall, I am strongly…

Overall, I am strongly opposed to this proposal. The government seems to be working with the mindset that species protection and growing the economy are mutually exclusive, yet that is not the case and greater time needs to be given to review this proposal. We can build the Ontario economy and protect species at risk AND our environment in a balanced approach that is not reflected in this proposal.

COSSARO:
- Strongly opposed. The government should not have say in what species are delisted. While the government has a great workforce with expertise, too often are their concerns and recommendations not consider, and too often are their proposals repackaged into something that fits the Premier's Office narrative. The power to change the list, particularly delisting a species, should not be in the governments hands. 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”:
- Strongly opposed. 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 for a slow and steady species decline because the animals are spending more time avoiding the harassment than reproducing, which is what we need in order to have a species recover. 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 continue to be considered under legislation.

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:
- Strongly oppose. 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. As an entity that provides funding to species recovery and habitat restoration, the province should be responsible for determining recovery progress and whether the province is meeting the benchmarks it sets out for recovery.

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.

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 effectively protecting all species in our province. There is a balance that can be achieved here, but more time is needed to effectively develop and consult on "outside the box" options that can achieve both species protection and 'unleash' Ontario's economy. This isn't it. This is fully unleashing Ontario's economy at the detriment of everything else.