We can be proud in Ontario…

We can be proud in Ontario to choose to build without sacrificing protected species and habitats.
Species protection and conservation should remain protected. We can work around species and habitats that needs protection; they cannot be moved as easily as humans. Economic growth in Ontario is possible with some effort to protecting species and places. We are smarter than simple bulldozers who flatten everything in their path – we can bend the path for the good of all living things. We can choose the higher road.
No activity should begin before approvals are in place; registration is not sufficient. I strongly disagree that activity could begin immediately after registering. Trusting people to adhere to the regulations before even having a permit is not an acceptable strategy. It is hard enough for the government to oversee activities with permits; it could hardly be reasonable to assume it could take on the extra workload of overseeing all the activities that have been registered. A “risk-based, proportionate, and progressive compliance model” requires time for risk assessment and cannot realistically monitor registered activity in a timely fashion. Risk-based means that not all activity is monitored which is not acceptable. None of this is something that upgraded IT systems can do. Every project needs minimum oversight by the government. We do not allow food establishments to operate without permits and oversight and we should not allow any development activity without permits and oversight, either.
The government should NOT have discretion to remove protected species from the list. I agree that the government may add species to the list. Any removals from the list should remain the purview of the Committee on the Status of Species at Risk in Ontario (COSSARO).
I do not agree with the proposed changes to definitions and requirements regarding “harassment” or “habitat”. The should remain as they are.
It is ridiculous to suggest that “Under the proposed new SCA, activities that are harmful to species” may proceed once “the person carrying out the activity has registered the activity.” Habitat for protected species should be protected until a full assessment is complete and a permit is issued for activity to proceed. We cannot easily rebuild habitat or re-locate it, so we must protect what we have now.
There is no duplication with federal law; we need the safeguard of both levels of species protection. Ontario has species that may not be included on the federal list, so species protections in the proposed Species Conservation Act, 2025, should continue to apply to SARA protected aquatic species and migratory birds.
We do not need to replace the current Species Conservation Program. Such an initiative is a make-work project and the time and effort required to set up a new program should be used to enhance the current one. Any residual activities and funds from the Species Conservation Action Agency (SCAA) and the Species at Risk Conservation Trust should be transferred to the Species Conservation Program and Species at Risk Program Advisory Committee. The funds should NOT be transferred to the government. The likelihood of the funds being spent “spent on activities that are in alignment with species protection and conservation goals” is most likely if the funds are allocated to the Species Conservation Program and Species at Risk Program Advisory Committee. The Species at Risk Program Advisory Committee should NOT be dissolved.