I strongly oppose the…

I strongly oppose the proposed changes to the Endangered Species Act, 2007. The quoted "unnecessary delays and costs for housing, transit, and critical infrastructure" in the proposal summary are from the lens of developers, not from the lens of Ontarians.

Protecting and rehabilitating critical habitat for a broad set of species is a complex process and therefore the decision to build or mine should also be a complex process.

I strongly oppose undermining the role of the Committee on the Status of Species at Risk in Ontario (COSSARO). The change appears to give the government the ability to add or remove a species at the government's discretion. This would mean that they could overrule COSSARO's decision and remove a species from the list. This is unacceptable. The decision to add or remove a species must be done by the team of qualified members of COSSARO using scientific knowledge, not by the government.

I strongly oppose removing the term "harrass" from species protections. We must keep the language strong to prevent the species from being harmed.

I strongly oppose the proposed changed definition of "habitat". An animal's habitat is not only their nesting/den/breeding/hibernating/etc region and the immediate surrounding area. The term "immediate surrounding area" is far too vague. Many of the species, especially birds, have expansive habitat needs. Larger animals will need larger areas to be able to find food, water, etc. Changing the definition of habitat is inappropriate and scientifically inaccurate.

I strongly oppose removing protections that are duplicated by the federal Species at Risk Act (SARA). Ontarians needs to have our own provincial protections in place. If the federal government decides to remove or change SARA, it is critical that Ontario's protections remain in place. It makes sense to need authorization from both federal and provincial before building/mining to ensure that the environment is not being compromised from both the provincial and federal perspective. Ontario's habitats don't end at our borders, and we have to remember that many species in Canada use habitats that cross our borders into other provinces.

I strongly oppose the "registration first" approach. Projects should not be able to start as soon as they have completed their online registration. They should have to wait for ministry review to approve the permits. The government should hire more staff to review permits to speed up the process that way. Under the "registration first" approach, Projects might destroy habitat before their application has been reviewed/approved. Once the destruction has occurred, it is irreversible. I urge the government to increase staff to reduce any wait times instead of introducing this registration first approach.

I am strongly opposed to the short 30-day period for Ontarians to submit comments on this. These are major changes and the government should be taking public consultation seriously. 30-days is too short of a timeline and it does not give Ontarians enough time to learn about and comment on these changes.