The proposed changes to, and…

The proposed changes to, and subsequent repealing of, the Endangered Species Act (ESA) will be absolutely detrimental to the environment. This is again Doug Ford putting development first at the expense of the environment.

Under the proposed new approach, instead of waiting for the ministry to approve permits, most proponents will be able to begin an activity immediately after registering. A registration-first approach for species-related authorizations will not work. We already have a registration-first approach for several types of undertakings which are not expected to result in significant environmental effects - the Environmental Activity and Sector Registry (EASR) - and there is not even enough government staff to audit the EASRs and make sure everything was done correctly. How can you possibly trust that proponents would conduct the appropriate species and habitat studies for the new registrations? Species and habitat are affected by nuisances such as noise and dust as well as direct construction impacts (habitat and species removal). By the time the Ministry of Environment, Conservation and Parks (MECP) staff get around to checking up on a registration, it will be too late to save species and habitat.

The Species Conservation Program to support voluntary initiatives like habitat restoration that protect and conserve species is great, but habitat restoration and offsets by proponents should not be voluntary. If proponents are going to destroy habitat, they need to create it elsewhere.

You want to "strengthen our ability to enforce species protection laws to ensure that all proponents comply with the rules and expectations of this new approach", but you do not have enough MECP staff now to even monitor large-scale projects, let alone every development that will be taking advantage of the changes to environmental permissions. We already have too little environmental oversight.

Regarding the government having discretion to add and remove extirpated, endangered, and threatened species to the list of protected species, who is "the government" in this case? Why should they be able to decide which species are on the list or not? That is what COSSARO is for, and the inclusion of species is based on factual data, not developer whims. The government should not be able to remove species from the list without consultation and hard data to back up the changes.

The idea to remove the concept of “harass” from species protections shows a lack of understanding of impacts to species and habitat. Species and habitat are affected by more than just direct construction impact and changes to air quality and water quality. Noise and light are both concerns that need to be addressed.

In short, this needs to be given much more thought.