RE: “ • for animal species: …

RE: “ • for animal species:
* a dwelling place, such as a den, nest, or similar place, occupied or habitually occupied by one or more members of a species for the purposes of breeding, rearing, staging, wintering, or hibernating
* the area immediately surrounding a dwelling place described above that is essential for the purposes mentioned”

The definition of a habitat is far too narrow and would inevitably harm any at-risk species. Dwelling, breeding and hibernating areas do not take into consideration, for example, access to water sources, foraging grounds, or migration corridors, nor do they take into account buffer zones (areas surrounding core habitats).

For example, an animal, such as a bird, may nest in one area, fly to another area for water, and forage for food in yet another. If you simply protect the “nest” and its general surrounding area, you could still be cutting that bird off from the food or water sources it needs to survive and to ensure its offspring will as well. Migration needs also do not seem to be taken into account in these changes.

In short, by narrowing the term “habitat”, you are broadening the amount of damage you will do to at-risk species and push ever more species to the brink.

Further, it doesn’t make sense to allow an organization to start a project that has not been properly vetted (re: “instead of waiting for the ministry to approve permits, most proponents will be able to begin an activity immediately after registering”). How does it make sense to allow an organization to do damage that may not so easily be undone before proper examination has been completed? This wording insinuates that a high level of trust is being placed in organizations that now have every motivation to say whatever needs to be said in order to get the preliminary permitting.

What happens, for example, when “registered activities” do not meet regulations? This too must be clearly laid out. If organizations think the likely risk vs reward will benefit them, then they will be incentivized to skirt rules, fudge paperwork, or simply pay off low-ball fines for their own benefit and to the detriment of the environment and at-risk species.

There are a lot of holes in this legislation. It should not pass.