The robust, science-based…

The robust, science-based approach to defining habitat that existed under the ESA, before the passage of Bill 5, must be reinstated before any guidance can be developed for assessing the impact of activities to a protected species or species’ habitat.
• The Ministry must restore the ESA and commit to strengthening protections for our most vulnerable species. The far weaker SCA is not the answer.

I understand the Ministry is looking for input on specific aspects of previous policies and technical direction to be retained; which components of the guidance is of greatest interest; which species groups would most benefit from habitat guidance; and, any other advice or feedback.
• Given the limitations to the definition of habitat under the SCA, it is unclear how such guidance can actually be applied in a way that benefits species conservation.
• To determine the possible impact of an activity, it is necessary to determine risk to survival of the species and habitat in question, as was included in guidance under the ESA. It is not possible to determine risk to survival of a species with any degree of certainty if all habitat (i.e. shelter, food, migration, reproduction, etc.) required for a species’ survival is not being considered in the assessment, as proposed under the SCA.