I am not happy with the…

I am not happy with the proposed changes to the Endangered Species Act of 2007. As I understand it registration of interested parties is to proceed prior to the development of regulations which parties will then follow. How crazy is this? Developers and others will feel free to move ahead on projects before appropriate assessments have been undertaken and the public and indigenous communities have had their say. And there is a serious lack of consideration of the bigger picture: the way aspects of environments form a whole from which species cannot be extracted: that is to say, species exist in eco-systems not abstract environments, they exist in interrelations with other species.

Regarding species classifications and listing, it is not clear to me how the government - with its ability to add or subtract items from a list of endangered or protected species, does not have the ability to override the decisions of the Committee on the Status of Species at Risk in Ontario (COSSARO), a body with the very scientific expertise needed to make these classificatory decisions. Nor is it clear to me the nature of the expertise with which the government would make its decisions - recommendations from the public or indigenous communities or ? I’d be happier if the process become more consultattive with the COSSARO retaining the deciding vote.

Re redefining protections.
-I would want further information regarding removal of the term ‘harrass’.
- I am not comfortable with the reduction of ‘habitat’ to the concept of a dwelling place and its immediate adjacent environment - major intrusion into an eco-system will have unforeseen impacts without a slow, well-thought-out process on the part of botanists and zoologists.

And I rue the wording used here: :Under the proposed new SCA, activities that are harmful to species cannot proceed unless the person carrying out the activity has registered the activity, or in limited situations, obtained a permit. Persons engaging in those activities must comply with the rules associated with the registration or permit. These activities include (see the activities indicated in your document at https://ero.ontario.ca/notice/025-0380) Surely this means once they have registered they can commit any of the activties you then list?

I agree that there may be some merit in reducing duplication of processes established by provincial (Ontario) and federal authorities. However, I would not be comfortable having the changes proposed here take precedence over those regulations originating in the federal section - especially given some of the concerns I have indicated above.

Running through this document one finds over and over a rush to give permission to profit-oriented investors/builders which enables one to circumvent existing restrictions. This is cart-before-the-horse thinking and I cannot support it.