Section 3-D: Proposal to no…

Section 3-D: Proposal to no longer require posting under the Environmental Bill of Rights and require that certain products be made publicly available on a government website.

This is a serious watering down of the rights and ability of the public to be notified and comment on proposed changes. I strongly disagree with this proposed change. While most people do not comment, I find the requirement to publicly post and accept comments under the EBR to be very much in the spirit of democratic representation and should be retained.

Section 4: The proposed change, if properly managed, has the potential to be a useful tool for conservation and allow for better provincial coordination of conservation targets. I do worry that the current government's intention is simply create easier ways for businesses to ignore species protection. I also worry that this will become the only tool, rather than one of several tools; this may be appropriate for some species in some parts of the province, but be completely inadequate or even counter-productive for others. Decisions need to be made on a case-by-case basis. Costs should be proportional to the size of the business involved. Multi-billion dollar corporations should be required to pay a proportionally larger charge than a small local business of individual. It is also essential that the Species at Risk Conservation Trust is not merely an arm of the current government in power, and that is is truly independent agency.

But if the government truly wishes to employ this in good faith, it could have many benefits for wildlife and businesses alike.

A red flag is that this leaves a lot of the decisions in the hands of the Minister's office, and removes much of the requirements for independent consultation. I think it is undesirable to allow for too many of these decisions to be make for political aims. That will be an unavoidable tendency for the Minister, who is, after all, a political appointment whose primary loyalty all too often seems to be to the party/government instead of the province as a whole. This is a concern for all parties, and was certainly an issue in the Liberal days as well.

Before allowing the Minister's office such sweeping control over this process, remember that the next Liberal/NDP/Green government will inherit these same changes and powers. We would all rather have a system that keeps enough checks and balances on the various parties (government and advocacy groups alike) so that we all feel reasonably assured that important decisions are make with input from across the province's various constituencies. Proposed changes to Ministerial control should be scaled back and more input/oversight retained.

Section 5-B: It is unclear what is being proposed. Enforcement is obviously a key component of protection, and Conservation Officers are relied upon for on the ground enforcement, particularly of hunting and fishing infractions. Proper enforcement — and the credible threat of punishment if rules are knowingly broken — must be maintained or strengthened.