I think these changes are a…

I think these changes are a terrible idea.
Ontario has some of the best Endangered Species legislation in the world. It is rooted in science and consultation with species experts and takes a habitat-focused approach. There are many difficulties in its administration however, and this has caused some issues with timelines and certainty. But, the proposed changes are short-sighted, not well developed, and will harm our species and ecosystems permanently for brief, short-term, financial gain of private companies.
I urge the government to reconsider. This proposal uses a one-size-fits-all approach to species habitat. Different species have different needs. While in some it may be appropriate to protect the nest or den, in others the migration habitat between breeding and wintering habitat is more crucial to protect. For vegetation the root protection zone may be appropriate on a large tree, but not for a tiny aquatic plant that requires that the water quality of its spring fed river be maintained.
I do agree that in recent years, as endangered species procedures have become more and more proponent led, that the lack of clearly defined habitat has been problematic. This however, can be solved by the government publishing clearly defined regulated or general habitat definitions for EVERY species IMMEDIATELY upon listing. The habitat is described in the COSSARO report, so the Government needs to legislate that the reported habitat will become regulated. This will save millions of dollars of consultation between ecologists and ministry biologists, in permit review, in revisions and delays at the last minute because a new SAR Bio has a different definition than their predecessor, etc. Establishing a framework of clear expectations and rules for proponents to follow is critical to the success of any species protection. So long as the rules are stuck to and enforced.
Importantly, I am concerned about the lack of well-developed registration conditions given with this proposal. What will these conditions look like? Will they be rigorous? Will species experts be consulted? What about the people who have to implement these conditions like developers and ecological consultants? What kind of consultation will be done? What will happen for registrations now that the Conservation Fund option is gone? Will there be a mandatory waiting period after registration to allow for audits (like with Butternut Health Assessments)? Will we move back to an overall benefit to species model? There are too many unanswered questions for me to support this idea.
I also agree that the COSSARO designation must match what is listed. But I truly hope that will not mean that the government will be interfering with COSSARO.
I agree that the DFO protects endangered fish and the duplication in protection is maybe not required. But the protection for Migratory Birds are a risk based model and are no-where near the level of protection required for endangered bird species and their habitats.
Lastly, this proposal gives far too much discretionary power to the government and the minister. These are not experts, they do not have the right information to adequately weigh benefit and cost for habitat.
I urge you, do not pass this bill. Go back to the drawing board and find a better way of administering the current ESA protections in a way that provides certainty and fairness for all involved.