I have several strong…

I have several strong objections to the proposed changes to the Endangered Species Act. Upon reading this proposal I have noted:

- the proposed changed would establish a new Species Conservation Program to support voluntary initiatives like habitat restoration that protect and conserve species

The idea that voluntary initiatives should be taking the place of mandated protections is absurd. Without rules and enforcement we know developers will not prioritize species or habitat protection, and the work of community volunteers cannot mitigate the damage that will be caused by industry.

- The government would also have discretion to remove protected species from the list

There is NO defensible reason why the government should have or need this discretion. This opens the door to further corruption and to making the entire concept of species protection in Ontario nothing more than a farce.

- Under the proposed new SCA, activities that are harmful to species cannot proceed unless the person carrying out the activity has registered the activity, or in limited situations, obtained a permit. 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 approach means a person can simply register an activity that will be harmful to a species, then immediately break ground on said project without any government approvals or public awareness or input. By the time the ministry has had the time to process the registrations the damage will already be done, and you as our government are fully aware of this.

- Ontario remains committed to species conservation and to promoting activities like habitat restoration, research, and community-based initiatives. This proposal would establish a new Species Conservation Program, which would improve upon and replace the Species at Risk Stewardship Program. Under the new program, 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. The program would also consider a wider breadth of supportable conservation activities.

This is passing the buck to community groups for drop in the bucket activities instead of holding developers to account and stopping the destructive activity from the get go. It is not on the community to voluntarily struggle to clean up the messes made by ill-considered and explicitly deliberate ignorance on the part of the government and developers. And $20 million is pennies.

The proposed new definition of habitat doesn't include any space for the animals, plants or other species to actually LIVE. Breeding, rearing, staging, wintering, or hibernating are the only activities listed. What about food procurement, and the understood movement and activity patterns of each species?

- the new registration framework will not include the option to pay a species conservation charge

What does the new registration framework require " when those conducting certain activities opted to pay a charge rather than completing on-the-ground beneficial actions for certain species."

- If harm to species occurs, the ministry has to tools to enforce the law and hold proponents to account.

What are they? It is important that these be clearly available for public review.

- the purpose of the ESA will be updated to drive species protection and conservation while taking into account social and economic considerations, including the need for sustainable economic growth in Ontario

The very use of the word sustainable here is an affront. It is not sustainable to gut species protections in the name of building subdivisions.