You think that by giving the…

You think that by giving the "Species Conservation Act" an appealing name that people will look past it and think that reasonable action is being taken towards species conservation. But we see through you. This is a sad excuse for species conservation legislation, and it would be detrimental to the well-being of our province. Below I've listed a FEW of my concerns with the proposed Act.

-Allowing an activity to begin before immediately after registering would effectively allow a free-for-all for development in critical habitat. If development is allowed without prior approval and they don't follow the requirements/regulations, the damage has already been done.

-Allowing the government to remove protected species from the list eliminates the entire purpose of the COSSARO list. If the government can remove a species' at-risk status, rather than adapting the project to minimize the environmental impact and protect vulnerable populations, they would remove it and continue development without further thought. COSSARO provides independent, science-based assessments of species in Ontario, and the government should not be allowed to ignore their ruling for the purpose of development.

-The proposed redefinition of habitat shows a clear lack of scientific understanding, not only of how a species utilizes its environment but also of ecosystem functions crucial for maintaining said environment. Most species are not limited to the area surrounding their den/nest/dwelling place. They move throughout the landscape to hunt, forage, mate, migrate, etc. This proposal claims to eliminate uncertainty, however, it fails to define what the "area immediately surrounding a dwelling place" is. Is it 1km, 1m, or less? This means that a fox could be considered "protected" in its den, while the entire forest around it is decimated, leaving no food, no protection, and no way of survival.

- As previously stated in the proposal, a project only needs to register to begin a project, and there is no approval process. With these proposed changes, that means that as long as the project is registered, it can carry out activities that are harmful to species. Once again, this renders all other protections useless.

- Recovery strategies and management plans, government response statements, and progress reviews are vital to ensuring that necessary action is being taken towards protecting species at risk. Removing the need for these allows the government to push conservation to the side and hold no responsibility for it.

- The Species at Risk Program Advisory Committee is an important part of implementing species at risk protections and legislation. Without it, the government is unchecked in its implementation of SAR protocol.

These are only the beginning of my issues with the proposed Species Conservation Act. The entire thing is riddled with a lack of scientific forethought and an apparent disregard for vulnerable species. It's clear the government's sole concern is profit and development. This proposal absolutely should NOT be approved, and I am wholeheartedly against it.