Section 2.A - The Minister…

Section 2.A - The Minister should not have the authority to temporarily suspend species and habitat protections for up to three years. This provides far too large a timeline for development projects to receive approval before a proper assessment can be made. The species should be automatically protected, with the authority of the Minister to conduct a scientific review over the three year period as to whether sections 2.A.i,ii and iii are met, and whether the habitat protections are necessary. The review should be conducted by the Ministry’s bureaucracy, not the Minister’s office nor a hired private firm.

Section 2.C - Since “when needed” is not defined, the mandatory legislative requirement and timeline to develop a habitat regulation proposal for each newly-listed threatened or endangered species should not be removed. This proposal removes any accountability to protect wildlife.

Section 2.D - The LGIC should remain the individual who makes species-specific habitat regulations.

Section 3.A & 3.C. - Remove accountability from the Minister’s office and should not be removed unless the length of time for the timelines is clearly indicated.

Section 4 - The Species at Risk Conservation Trust does very little to reduce red tape faced by municipalities and other infrastructure developers. Having to pay a fee similar to the cost it would otherwise incurred through meeting the species-based conditions of authorization does not reduce the cost of doing business in Ontario. It may fast-track development bit a small margin of time, however, the long-term detriment to the affected at risk and endangered species does not outweigh a minor change in development timelines. In addition the proposed change states that the activities used by the funds would be with an agency that would “ensure informed, unbiased and exert decisions”, however, the Minister is set to be able to “establish guidelines (e.g. objectives and priorities) for funding and set standards for activities that receive funding”. This provision makes it impossible for the agency to be unbiased/non-partisan while conducting this work.

Section 4.A & 4.G - These provisions give far too much control to the Minister and should removed. Making Ontario open for business means making a consistent set of rules that businesses can rely upon. Having the Minister maintain so much control over the permitting process and proposed regulations impact on species removes the consistency needed by business. As governments change, Minister’s opinions on matters will alter widely. Having the Minister always consult an independent expert removes partisanship and gives stronger consistency for businesses.