A registration-first…

A registration-first approach opens the door for significant harm to our province's most at-risk species. The government should immediately scrap the proposed procedural changes and should revert the prohibitions and approval process to as they functioned in the original Endangered Species Act (ESA). The provincial government has spent their time in office systematically removing all of the environmental protections that provided any benefit to species. The strongest aspect of the original ESA was its automatic listings and protections, both of which are now gone to the benefit of the province's wealthiest and most environmentally-damaging corporations. The issues with past approval systems was purely in the implementation, a problem which was manufactured by the present government. The government drastically reduced the amount of employees in charge of approvals (see link below), was already fast-tracking development approvals while delaying conservation-related approvals, and continuously expanded activities that were automatically exempt from permits and approvals anyways. Government employees also had no guidance on when approvals should be rejected, resulting in automatic approvals. The only difference now is that proponents can harm the environment sooner and easier. The system needed to be fixed with proper staffing and guidance on the permitting process, not completely razed. As the government stated in their own ERO posting "Under the proposed SCA, almost all activities that currently require a permit before proceeding are anticipated to instead require registration. It’s important to note that a registration approach is already in place and used by the ministry for 95 per cent of projects subject to the current ESA, including early exploration mining and species surveys." So not only does this not solve the implementation problems, it means worse outcomes for species at risk. Presently the government does a poor job at following through on existing permits and approvals, so we already have no clue if development proponents are following the already weak rules. Although the government states that registerable activities will have rules that protect species that need to be followed, they have not created the conditions to allow for actual accountability and monitoring for compliance. Permits to harm species at risk are not legislative red tape, they are important safeguards that already balance the needs of society and the rest of the natural world. The new approach all but guarantees that species at risk will not be taken into account when conducting harmful actions to the environment. Ontario needs to protect our species at risk, not allow developers and corporations to steamroll their habitats and reduce their populations even more than they already are. Permits should still be required, and compliance monitoring and oversight should be increased so that protections for species at risk are actually enforced and those who contravene are actually punished for their actions. The rules outlined in permits and registerable activities should be strict and should result in benefit for the species. The government provides no indication that species at risk will benefit in any way from this registration-first approach.

https://www.auditor.on.ca/en/content/annualreports/arreports/en21/ENV_P…