While I am not opposed to…

While I am not opposed to streamlining bureaucracy and I agree that the current ESA permitting system can be onerous and overlap with other legislation, the proposed changes go too far in my opinion.
Specifically:
1. “the government will have discretion to add species to or remove from the Species at Risk in Ontario (SARO) List
o science-based assessments by COSSARO will continue
o ESA authorizations for aquatic and migratory birds that are protected under SARA continue to be required until the new SCA is enacted”

Even if the COSSARO science-based assessments continue, there is no commitment to following these assessments in the consideration of removing or adding species by the government. Who in the government is going to have this responsibility? Are they bound to follow what experts (e.g. COSSARO) recommend in making changes to the SARO list?

2. “the requirement for the government to develop recovery products for species will be removed from legislation enabling a more flexible approach”

Unfortunately, a “more flexible” approach can lead to less protection for species on the SARO list.

3. Implementing a registration model is too much like making it easier to ask for forgiveness than permission. What type of oversight will there be for activities that are subject to registration rather than permitting to ensure that Species at Risk and/or their habitats are not impacted?

Thank you for considering my comments.