As a professional ecologist…

As a professional ecologist I am very concerned overall about Bill 5 and the environmental aspects of ERO 025-0380 - the removal of the ESA and replacing it with another act. My concerns include;
• That the provincial government can decide to remove a species from the COSSARO list is unacceptable given that COSSARO is the body that has the scientific knowledge to list species
• That the funds from the Species at Risk Conservation Fund have not to date been spent on SAR and it appears that these funds might get spread thinly and not serve their original intention
• That the new Species Conservation Program has an emphasis on volunteer work, which while worthy, is not the best way to protect SAR. There should be funding going into scientific research, and targeted paid studies.
• Despite the provinces’ need for new housing, the ‘economy’ should never be ‘unleashed’ onto the natural environment, which will always require protection for its own worth as well as for human benefit (a clean, functioning natural environment)
• To change the definition of animals’ habitat to include ‘the area immediately surrounding a dwelling place described above that is essential for the purposes mentioned’ is both worrisome in its vagueness and subject to being determined to be something too small for a specific animal to function within.
• There is no clarity on how species will be protected under the registry process – will habitat, or some other compensation still occur?
• Removing the ‘requirements to develop recovery strategies and management plans, government response statements, and reviews of progress from legislation’ implies that your government is not concerned about SAR. This is too much of a step backward.
• It’s difficult to determine some of the outcomes of these proposed changes as ‘New regulations are required to implement the SCA’s registration model and will be consulted on as necessary.’ There is too much uncertainty about the direction being taken by your government; what will the regulations say?
• There is a lack of clarity regarding what species are protected under the new proposed SCA as in more than one place it refers simply to ‘species’ and species at risk’
• That the ESA is being replaced with an act called the Species Conservation Act (SCA); this downplays and waters down the importance of those vulnerable Species At Risk (SAR)
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I do agree that duplication of permitting between agencies at different levels is overly cumbersome and not necessary,
I don’t think the proposed ERO and associated parts of Bill 5 should go forward. Amending the ESA to improve efficiency would be a better way forward. In addition to removing duplication, I believe that an important change to the ESA would be to allow overall benefit to be directed towards research and other means that might protect species and not just provide habitat replacement that is sometimes ineffective (e.g.Barn Swallow structures, Chimney Swift towers, unfocussed bat compensation etc.)