The following comments are…

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025-0380

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148158

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The following comments are also in the attached PDF file. I have included it because this comment box does not allow the formatting that I would normally use to emphasize certain key words or phrases. Such emphases are shown in the PDF.

Regarding the repeal of the Endangered Species Act 2007 and its replacement with the Species Conservation Act 2025:

These excerpts are quoted from the Government of Ontario Environmental Registry website, under “proposal details” for Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025:

https://ero.ontario.ca/notice/025-0380

“Under the current Endangered Species Act, 2007 (ESA) program, the process to obtain a permit is slow and complex, causing unnecessary delays and costs for housing, transit, and critical infrastructure.”

“Under the proposed new approach, instead of waiting for the ministry to approve permits, most proponents will be able to begin an activity immediately after registering.”

The whole point of having to obtain a permit is because of the possibility that a proposed action may be detrimental to the environment, and should be amended or stopped entirely. The changes proposed by the Species Conservation Act 2025 circumvent that essential check, and allow a proponent to begin work before approval has been granted. If it is later determined in the permit granting process that environmental harm would occur due to that work, it will be too late to stop it or reverse that damage. By putting such a possibility in place under this new legislation, it is clear that Premier Ford’s Conservative government has no intention of stopping work, that they deem essential for Ontario’s economic growth, even if it could or will cause environmental damage. The “slow”ness of the current process is essential to allow for research, public consultation, assessment of risk to species and overall protection of environmental assets that can never be restored once they are destroyed. It is quite possible, and immensely more preferable, for the expansion of “housing, transit and critical infrastructure” to be done, from the outset, with an eye to environmental protection, not with an attitude that environmental protection is merely an annoyance or inconvenience.

This legislation is fundamentally abhorrent in this respect, and must be withdrawn immediately. Any government with any conscience would do so.

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