I strongly object to all of…

I strongly object to all of these proposed changes to the framework for managing species at risk, and suspect that if this change to policy is implemented as proposed, that many species (particularly in southern ontario) will suffer significant declines in population abundance and distribution. Once gone, these species are unlikely to return, and will no longer be a part of Ontario's natural heritage and cherished identity.

Although I vehemently disagree with almost every suggestion in this policy, I have specific comments towards the following proposed changes:

- Reducing the functional definition of SAR habitat to an area immediately surrounding a den, is likely to result in habitat fragmentation and ignores the spatial needs of many species to move within a broader range to meet all needs within their life cycle. You cannot simply isolate a den/nesting space, and declare that because you have not developed that one space, that an animal has not been harmed, killed or harassed. Infringement on adjacent lands to known SAR habitat may also preclude the ability of species to survive there, and still represents degradation or destruction of the functional ecology of that space. I suggest not redefining SAR habitat.

- Moving to a registration-only system, that bypasses the objective-review process, is ill advised and unsustainable. Further, you have provided no evidence on how species have been effectively protected, and to what extent, in situations where this approach has already been implemented.

- Suggesting that the current review and approval system is "too rigid" and "overly confusing" is vague, and suggests that industry professionals lack the capacity for advance project planning, or preliminary scoping activities. This is likely untrue, and is not a legitimate reason to overhaul an entire review process. The correct response to confusion, is to provide more information, education and awareness- not just repeal all the checks and balances currently in place, to reduce impacts to vulnerable species and the ecosystems they inhabit.

- Eliminating the Species at Risk Advisory Committee significantly reduces the ability of stakeholder groups, communities and constituencies to provide advice to process within the decision-making framework. This may not even be legal, and certainly, defies the intent and purpose of a public service agency working on behalf of the people.

- This entire proposal is framed in a way that suggests that increasing corporate profit margins is a higher priority for the people of Ontario, than protecting and sustaining the land and species we share space with.

These species, and the systems they inhabit at present, are entwined with our provincial and national identity. An attack on them in the name of rampant development, is an affront to any objective, informed, and progressive democratic process.