The registration first…

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025-0380

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147054

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The registration first approach will be detrimental. No one should start project activities until a proper assessment has been completed. This sounds like a way to get around doing things properly and actually protecting species.
The purpose being updated to include "social and economic considerations" is unnecessary and misleading. Social and economic conversations are already taken into account, often too much. The ESA's sole purpose is to protect species, and that's all it should be about. Because a reduction in biodiversity will adversely affect our social and economic needs, and we are having a biodiversity crisis that will be much worse down the line if we don't take action now.
The government should not be allowed the discretion to add species to or remove from the Species at Risk in Ontario (SARO) List, the purpose of the listing process is to ensure it is science-based. If species can be added pr removed at will, then they will be removed whenever it is inconvenient for business. This is not okay, and as a citizen I am completely against this.
Harassing species at risk should absolutely be prohibited, and "harass" should not be removed from the list of prohibitions.
I do feel that the requirements of recovery documents could be simplified or streamlined in order to be more efficient.
The Species at Risk Conservation Fund should accept funds and also proponents should be required to pay a charge, however, they should not be allowed to opt to pay instead of doing completing on-the-ground beneficial actions for certain species. I think we should be strengthening the SCAA and the Species at Risk Conservation Fund to complete species at risk projects and to fund scientific efforts. It is greatly needed, and if no projects have been funded then maybe that needs to be looked into as to why that is. Because species at risk science is significantly underfunded and I know there are many projects that could use that money. And the corporations that do projects that disrupt species at risk should pay for additional reparations, including scientific research and restoration for species at risk.
Overall, the changes to this act seem to be reducing protections for species at risk when we should be strengthening them. The Ontario government seems to be focused on development and is disregarding species that are vulnerable, like the Redside Dace. If we lose these species, they are gone forever. If we lose our biodiversity, it will impact our economy, our culture, and it will be irreversible.