The proposed changes to…

The proposed changes and new legislation, which seem to ignore established science, will cause a massive loss of species, habitat and biodiversity and will not benefit Ontarians in any of the ways that they claim.

The changes/new legislation define "habitat" too narrowly and miss critical habitat areas used by species at risk - e.g. for fauna, they ignores habitats used for activities like obtaining food material, migration, predator evasion etc.

The proposed "registration-first" approach (akin to "it's easier to ask for forgiveness than permission") is very problematic. If species at risk are later discovered at such a "registered" project, it's quite likely the investor money tied into the project will result in the government making exceptions or removing the species from the Species At Risk list (see below)

The proposed changes (and new Act) also let the government summarily remove species from the Species At Risk list - no reasoning needs to be provided! This provision makes one question if there is even a point in having a Species At Risk, if removal is so easy!

I strongly believe that for the best outcome for Ontario, the current Endangered Species Act, 2007 (ESA) should remain untouched and the proposed Species Conservation Act, 2025 (SCA) should be scrapped completely.