This proposed change to the…

This proposed change to the Endangered Species Act is a blatant and lazy undermining of the scientific rigor and expertise brought to the table by environmental professionals.

First and foremost, the 'Registration First' approach is nothing but a way to streamline the irresponsible destruction of important habitat, allowing developers and corporations to put their own profits before any sort of consideration or due diligence related to environmental compliance. I am also concerned that this will translate into a shortcut around the duty to consult - which is not only LEGALLY OBLIGATED for all entities conducting work on Indigenous Territories & Treaty Lands, but ETHICALLY IMPERATIVE. Further, the existing systems in place are an important barrier for developers and corporations in order to provide time for oversight and due diligence. These for-profit companies need to be held accountable to moving at the speed of due process, not at the speed of their own greed.

Additionally, adding in the ability for the government to remove species at risk from the list of protected species is outrageous. COSSARO exists to bring together subject matter experts, using their valuable time and knowledge to advocate for species at risk. External government officials who may or may not have the appropriate training and/or knowledge to make decisions concerning the de-listing of individuals should not be acceptable. Not only is this poor judgement, but it wastes the time and effort of those contributing to COSSARO.

Removing the term 'harass' and redefining habitat to include only the most immediate vicinity of an individual would be a grave error, serving only to benefit developers by allowing them to 'phase out' species at risk individuals by encroaching on their required habitat over time. Individuals of all species require habitat beyond just their 'denning' sites and the immediate vicinity - they require a species specific range in which they obtain necessities such as food, water, shelter, mates, etc. For some species, this range is just a small area, but for others it encompasses a wide range; further, many species travel over time, and require a larger range in which they can move about annually. Similarly, plant species require more than just the immediate vicinity of their root system; they require adequate space to disperse and spread, as well as healthy soil and water, and access to sunlight - all of which could be negatively impacted by nearby development within habitat range. The term habitat is vague, however this is important for allowing experts to apply important context and species specific information to inform what is required on a case by case basis. While it may be considered confusing to just anyone, that is the reason there are experts on hand - and these experts, who understand the terminology and nuance of these directives, should be the ones who are able to guide decision-making and approvals. You wouldn't allow for safety directives to be simplified to a point where they can be misinterpreted for the sake of what is easiest - why should it be allowed when it comes to the environment? Rigor and oversight by subject matter specialists are important for this reason specifically.

Finally, suggesting that these amendments will increase capacity for enforcement of infractions is truly laughable. I would like to know how exactly these enforcements will occur, and what the government will do once work has already been undertaken through the 'registration first' approach. Even if projects were halted, much of the damage would already be done. Yet another example of the government enabling companies to 'pay to play' and exchanging money for the ability to destroy our incredible Ontario landscapes.