I first want to state that…

I first want to state that this Act is clearly not designed to protect species at risk and there habitat, but to make it easier for the government and industry to exploit natural resources without the proper mitigation and consultation.

All developments and activities altering or impacting the landscape should be required to obtain a permit. Permitting ensures that there are proper risk assessments, mitigation efforts, and consultation with Indigenous peoples where free, prior and informed consent must be obtained. Allowing registrations and exemptions instead of permitting effectively allows a free-for-all for development in critical habitat. If development is allowed without prior approval and they don't follow the requirements/ regulations, the damage has already been done.

Culturally important species should be protected alongside those listed at risk, which allow Indigenous peoples to exercise their Treaty rights. Decisions about all species, habitats and protections, should be made with Indigenous communities as partners with an active role in the decision-making process.

Bill 5 has weakened the definition of habitat and guidance measures made following that definition will be inadequate. The redefinition of habitat shows a clear lack of scientific understanding, not only of how a species utilizes its environment but also of ecosystem functions crucial for maintaining said environment. Most species are not limited to the area surrounding their den/nest/dwelling place. They move throughout the landscape to hunt, forage, mate, migrate, etc. This Bill claims to eliminate uncertainty, however, it fails to define what the "area immediately surrounding a dwelling place" is. Is it 1km, 1m, or less? This means that a fox could be considered "protected" in its den, while the entire forest around it is decimated, leaving no food, no protection, and no way of survival. Both scientific evidence and Indigenous knowledge must be utilized to define and protect a species and its habitat.

Furthermore, a concrete definition of adverse impacts is needed to ensure that no harm comes to our vulnerable species as a result of vague definitions that can lead to different interpretations.