"Everything you are doing is…

"Everything you are doing is bad. I want you to know this."

I wouldn't have thought that a classic line from 1989's Ghostbusters II would be relevant to a government consultation, and yet here we are. Let's dive in:

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"...the [current] process to obtain a permit is slow and complex, causing unnecessary delays..."

See, no. When it comes to protecting species at risk, there is no such thing as an "unnecessary" delay. Taking the time to assess each and every potential impact of each and every proposal is the whole point of having legislation.

"To help speed up project timelines and provide greater certainty for proponents..."

Why on earth should there be certainty for anyone who is looking to harm an at risk species? This whole intro paragraph is one big giveaway of the fact that even the current legislation already fails to prevent developments that simply shouldn't happen. Not every harm can be mitigated; many simply have to be prevented in the first place.

If you'd like to speed the process up, hire more people with the necessary environmental and biological expertise. Look at that - bonus job creation!

"The Protect Ontario by Unleashing our Economy Act, 2025"

Can you hear yourselves? One of the primary roles of government at any level is, yes, to protect, but it's to protect the interests of the common good THROUGH REGULATION. You are proposing to actively harm Ontario by destroying our ecological health by giving profiteers free rein to tear up our irreplaceable wetlands, meadows, forests, and to start on infrastructure projects that ignore the fact that climate and ecosystem collapse is barreling towards us. You know, "unleashed" by the disrespect we've already shown to our cousins in nature.

"...the proposed changes would provide a reasonable, balanced approach to protecting species..."

Again, this legislation is not supposed to be balanced, it is SUPPOSED to be on the side of the species at risk. It's the only part of our system that is!

"...shift nearly all species-related authorizations to a registration-first approach..."

Which again assumes all projects should go ahead, and all mitigation plans created by the developers will be sufficient. Which they should not and will not.

"...setting clear expectations and rules for proponents to follow, ones that are focused on those activities that are most likely to have a direct negative impact on species..."

This is incredibly reductionist and harmful. Ecosystems are endlessly complex; only focusing on "direct negative impacts" suggests an absolute failure to understand that.

"...a new Species Conservation Program to support voluntary initiatives like habitat restoration that protect and conserve species..."

Who is doing the volunteering? Why isn't this something government is either mandating or doing itself? If you want to support volunteer environmental community groups, that's great, but everything they do should be a bonus. The actual work of species recovery (no, not just "conserving" what's left, but increasing populations) should be the responsibility of the government and the companies required to mitigate their own harm.

"....strengthen our ability to enforce species protection laws to ensure that all proponents comply with the rules and expectations of this new approach..."

Better enforcement would be wonderful, but it only matters if the rules and expectations are actually useful themselves

"...Registered activities will be required to meet all associated requirements set out in new regulations. The ministry looks forward to developing these regulations in consultation with the public and Indigenous communities over the coming months."

The requirements to protect any given species are going to be different, and should be constantly re-evaluated and updated. Consultation is great, and necessary, but if all it results in is watered-down rules that are "balanced" and apply broadly to "direct harms," Ontario's species will pay the price.

"The purpose of the species protection legislation will be to drive species protection and conservation while taking into account social and economic considerations, including the need for sustainable economic growth in Ontario."

Again, no. It's purpose should be to drive species protection, conservation, and RECOVERY, and then the sentence should end.

"The role of COSSARO ... will not change. However, ... the government would also have discretion to remove protected species from the list."

So the role of COSSARO would change. This is by far the most appallingly offensive suggestion in this proposal. Great if the government wants to add species. You should have ZERO power to remove species.

If you're planning to make changes though, COSSARO should be given the staff, support, and funding to move much more quickly in their evaluations, and their updates to listings should take effect IMMEDIATELY when a report is issued, not when the government gets around to it.

"...We are proposing to remove the concept of “harass” from species protections..."

Why would you remove this? You don't think stress is a factor in the survival of an individual animals? If there's someone living where I want to build, why don't I just harass them into leaving then? Problem solved, yes?

"Also, the definition of habitat is proposed to be reframed as follows..."

And then what follows is most definitely not the definition of habitat, by anyone's standards. Animals need food, they need to be able to move through connected spaces to find mates, they need clean water; most plants need to be close to others of the same species for pollination to occur, and they need pollinators in the area; then for a species to recover they need room for their seed to spread; they need the right amounts of sunlight and rainfall or groundwater; we're learning more all the time about underground mycorrhizal network. Dens and rootballs do not a habitat make.

"...We are making these changes because the current definition of “habitat” creates uncertainty, includes broad areas..."

Including broad areas is the correct definition of habitat.

"Under the proposed new SCA, activities that are harmful to species cannot proceed unless the person carrying out the activity has registered the activity..."

Are we going to start applying this to other supposed protections as well? Like, if I want to dump some toxins in a river, will I be able to just register the dumping and go for it?

Go ahead an update IT systems, that's great, but companies should absolutely have to wait for approval before starting an activity. It's upsetting to find out that this ISN'T currently the case much of the time.

"...possessing, transporting, collecting, buying, selling, leasing, or trading a member of a species listed on the Protected Species in Ontario List..."

No one who isn't a CAZA accredited zoo, a licensed wildlife rehabilitation centre or sanctuary, a researcher following VERY strict guidelines, or working on an approved recovery project should be doing those things at all. And not even those organizations should be buying, selling, or leasing. Leasing??

"...To remove this duplication [with the Federal government], species protections in the proposed Species Conservation Act, 2025, would not apply to these SARA protected aquatic species and migratory birds, allowing for projects to move forward in a more efficient and cost-effective way...."

While clearly this government is never going to demand STRONGER protections then the feds for some species based on traditional knowledge or local circumstances, future provincial governments might like to have that power, actually.

"...The proposed amendments to the ESA would remove the requirements to develop recovery strategies and management plans, government response statements, and reviews of progress from legislation..."

Okay, this is a close second for most appallingly offensive suggestion in this document. EVERY species should get a recovery strategy and ongoing review will always be necessary if any of the species are going to last another thirty years much less seven generations. Hire more staff and make recovery, not conservation, the goal. Create an Office of Species Recovery and give every species on that list their own staff person whose whole job is bringing that species back, with the support of the biologists, ecologists, and community engagement specialists employed by that office. Be transparent about progress, and setbacks. None of this is going to fix itself, and "conservation" it not enough.

"...the government intends to increase investment in supporting voluntary activities that will assist in the protection and conservation of species by more than four times, up to $20 million per year..."

Increasing investment is great. Relying on voluntary actions isn't.

"In September 2021... To date, the SCAA has been focusing on starting-up its operations and has not spent any funds on projects..."

Three and a half years, eh? Are you planning to divulge how much is sitting in this fund, unspent, plus how much interest it has earned in that time?

"... transferring the money in the Fund to the government and requiring it to be spent on activities that are in alignment with species protection and conservation goals..."

'In alignment with' is incredibly vague and suggests it will not directly protect species at all.

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The Endangered Species Act could use improvement, but none of these proposals are doing that. Recovery plans are not only necessary, they should be fully funded and properly staffed. Activities that can harm species should absolutely be required to go through a permitting and approval process, with the understanding that some permits will be denied. A systems thinking and one health approach is needed when considering habitats and potential harms. Better enforcement, including significant fines and potential jail time, are all great, but only if the rules being enforced are doing what they need to do in the first place. Support COSSARO and respect their decisions with immediate action. Invest in species recovery. Build wildlife crossings where they're already needed before you start thinking about new roads. Employ scientists and young labourers side by side in restoration projects. Do hold public consultations, but use them to more community-sourced knowledge about species and take ideas for where government-funded recovery projects can take. And yes, support community actions, but don't put the responsibility to Save Our Species on volunteers. These are not inevitable losses. Don't just pay lip service to the problem until it slowly goes away, one extirpation or extinction at a time. We can do so much better than this.