I find the current proposed…

I find the current proposed changes questionable, given that the current Provincial Government, led by the current Premier, crippled the implementation of our existing Endangered Species Act, 2007 (ESA) through their changes to its permitting authority. The worsened chaos and exorbitant timelines for ESA permitting within the development circuit in recent years rest squarely on the shoulders of our current Premier, who here appears to be claiming to be providing a "solution" to his own problem in the form of this law revision.

The ESA had been - prior to the current Provincial administration - previously administered by the Ministry of Natural Resources (MNR/MNRF) ever since the ESA was first passed. The MNR is a provincial agency filled with knowledgeable staff well-acquainted with provincial natural heritage, including our species at risk (including Endangered and Threatened species), from both a scientific standpoint as well as a permitting and legal/ESA standpoint. This ministry had the staff and experience to respond to inquiries within a matter of weeks, and respond to permitting discussions within a matter of months. Their implementation of the standards under the ESA were also comparatively nuanced, and they had the knowledge and background to address detailed considerations relating to the species they were permitting for.

ESA permitting authority was then forcibly removed from MNR jurisdiction by the current Premier's administration, and given to the Ministry of the Environment, Conservation and Parks (MECP) for little compelling reason. Permitting authority was given to a very small team of new staff with, apparently, little to no knowledge-transfer or staff-transfer from the MNR. Even though MNR retains (to this day) the database with all the actual data on Endangered and Threatened species, and had in-depth experience arguing the boundaries of the ESA and applying the legal powers of the ESA, the MECP was abruptly charged with implementing the ESA, seemingly from first principles.

Permitting timelines shot up for all of us in the environmental permitting circuit. The MECP Species at Risk branch, to this day, sends out emails claiming they will attempt to respond to basic inquiries within 100 business days (approximately 20 weeks, or 5 months), and we have been indicated that individual biologists addressing permitting processes have such a high backlog of work that the initial response to the first step of the permitting process (an Information Gathering Form) may not be evaluated for comment/review for over a year. Further, the MECP's interpretation of the ESA and its standards is quite different (and more stringent) than the MNR , and so more projects were suggested to require permitting in the first place.

The current administration's self-imposed changes up to this point have disproportionately extended permitting timelines and permitting costs to the same developers the Premier appears to be attempting to 'help' with this legislation change. Perhaps a cynical citizen might be forgiven for wondering if the implementation of the ESA was intentionally made to be slower, more expensive, inefficient and worse overall specifically so the current administration could gain support to propose aggressive changes to the law itself.

I do not support this policy change, as I believe this change stems from self-imposed problems due to either the incompetent mismanagement of our provincial ministries and their services, or bad faith action by the premier to intentionally build up public and industry support to defang Endangered species protections.