I strongly oppose this…

I strongly oppose this attempt to place development, and economic advantage, above properly protecting the most threated species and populations in Ontario.
1. Amending the purpose statement of the Act. The purpose statement of any Act is critical to how the Act will be applied - i.e., what is in scope and what is out of scope and how decisions will be made. The new Act will have an amended purpose that includes the phrase "to provide for the protection and conservation of species while taking into account social and economic considerations including the need for sustainable economic growth". This means that sustainable economic growth will override the protection and conservation of [endangered] species where there is conflict between the two - this is not an appropriate approach to protecting endangered species, especially during a climate crisis.
2. Move from permits to "rules-in-regulation" approach. Under the new approach a person (including a corporation) will not require a licence or permit to start work that may have a negative impact on an endangered species, or its habitat, if they first register the activity and then follow the generic rules in regulation. A rules-in-regulation approach is simply not appropriate where individuals in a population, or the habitat they depend on, are seriously endangered - each individual organism and its habitat is important. Since the individual endangered specimen may be limited by things like site specific conditions (e.g., water quality, quality or chemistry; site slope; associated vegetative cover; etc.) it is impossible to create effective generic rule-in-regulation. Similarly, a registry system is generally an unmonitored system. At best the registry is reviewed occasionally for completeness but seldom, if ever, results in field level compliance inspections. An unmonitored registry, supported by generic conditions, will provide no protection for our most vulnerable species and populations.
3. Discretion in the listing process. In the current ESA listing process species are considered using a science lead approach. COSSARO (the Committee on the Status of Species at Risk in Ontario - an independent body composed of subject matter experts) reviews and discusses species that could potentially be ESA listed. If COSSARO puts forward a species for listing the government is obliged to list the species under the ESA and to develop regulations and a recovery strategy for the species. Under the amended Act the Minister will have the discretion to list or not list the species recommended by COSSARO based on the purposes of the Act (i.e., the need for sustainable economic growth). These are species that may take decades to recover, even with proper protection. Political expediency and economic value is not an appropriate consideration when it comes to protecting our most threatened species.