While I understand the need…

While I understand the need for speeding up the process of permitting in the case of species with a COSSARO status, I object to three specific areas of the new proposal:

1. Immediate work can be completed after registration. I think that this makes a bit of a mockery of the previous act, because if there is an endangered species or one with needed protection there, then it will be destroyed, somewhat preemptively, prior to any potential to perhaps change development plans slightly (e.g., park areas, natural corridors), to protect the species.

2. No protection zones. This is also a very bad idea as species move around or need space to colonize in the event of extirpation or climate change in for example, southern areas. I can't think of a place in the province of Ontario where there would be no species of concern. This seems like wishful thinking on the part of the government.

3. Retaining COSSARO but having the government decide which species have some protected status. COSSARO should be independent, and open to any academic or government scientist (so I think it needs a rehaul.). COSSARO should act as the deciding body (in a new formulation or at least to have those people who have a background in conservation biology). The government, unfortunately, can be seen as opportunistic in saying whether a species should or should not be, depending on whether they would like the development to proceed. This part of the proposed act is the most egregious in terms of its impacts on species at risk. I also think that there would be a real question of populating COSSARO if in fact, its recommendations have no meaning and the government would eventually decide.