These proposed changes are…

These proposed changes are absolutely unacceptable. While there could be improvements to the ESA in several ways, most importantly the investment in more government staff to process permit applications - the changes proposed are an enormous step backwards and should not be allowed to proceed.

These changes will not at all protect our economy - in fact they will put our economy in jeopardy. Our economy, and even our survival, depends on the environment.

Politicians should never be granted authority for issues of a biological nature - these must be addressed by experienced, unbiased professionals. If politicians can make decisions from an economic perspective that override species and habitat protections - this leads to government corruption an will destroy the environment that we depend on in a resource-based economy. This includes the government's ability to decide if a species listed by COSSARO is added to the act and afforded protection. COSSARO is an independent body that makes these decisions, which cannot be over-rided by government. The current system should prevail until extensive consultation on potential improvements can be completed. Also important, the government should not have the authority to remove any species that is already assessed and listed by COSSARO.

The government MUST have a responsibility and accountability to protect and restore species. Removal of the requirement for recovery strategies, government response statements and agreements is unacceptable. These requirements are independent of any project permitting and have no impact on economic issues, but simply absolve the government of responsibilities they SHOULD have. Without these documents, proponents and consultants have no direction on the species-specific ecological requirements, direction for recovery and means of protection for the species or the habitat.

The definition of habitat must not be refined. This allows for impacts to species life process that will drive them into further decline. Equally important, the term 'harass' must remain in the Act. Activities that harass an individual of a protected species will inherently inflict 'harm' and abandonment of habitat. Therefore 'harm and harass' are correlated and the language to include both terms must remain.

Enforcement officers must retain the authority to issue stop orders if there is any potential for impacts to species or habitat.

This proposal opens the door for federal government overstep for the protection of species. If the proposal moves forward, the federal government MUST impose the Species at Risk Act to ensure protection for species that the provincial government is attempting to side-step. It would be embarrassing that the provincial government would expose themselves and all proponents to this risk.

Overall, this proposal is appalling. It should not be allowed to proceed. The Endangered Species Act must remain in force in its current state. Improvements to the Endangered Species Act can be made, but should start with extensive consultation with all parties involved, including proponents and consultants, but also indigenous communities, environmental NGO's and unbiased citizens of Ontario.

Please withdraw this proposal!!!