"the government will have…

"the government will have discretion on what species are protected"
Are members of provincial parliament qualified to make these decisions over COSSARO? What criteria will they be basing their assessments upon? Will having the protected species list fluctuating every time a new government comes to power reduce uncertainty for developers?

"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."
This needs to be thought out quite carefully with the registration processes reporting requirements, as provincial agencies will no longer have the opportunity to request further studies be conducted prior to clearing. How will the new legislation prevent people claiming no protected species are present, registering, then clearing the land (and evidence)?

"Registration (or permits) will no longer be required for impacts to migratory birds and aquatic species protected under the federal Species at Risk Act"
Is abdicating control of environmental protections to a different government body a responsible thing to do?

"Some activities may be excepted and others may be required to obtain a permit if they are prescribed by regulation"
Which activities, is the list of exemptions expanding from what is currently exempt from the ESA?

"The definition of habitat is proposed to be reframed as follows: for vascular plants species: the critical root zone surrounding a member of the species"
Habitat required to support at risk plant species almost universally exceeds their critical root zone. Most species at risk are at risk due to habitat loss, not impacts to their CRZ. This effectively removes protections for all protected plants, just clear around them, wait for them to die (due to lack of canopy or fungal associates, higher winds, drier microclimate etc.), then proceed with development next year.