I have a few questions and…

I have a few questions and comments:

* are species of special concern not even on the SAR list anymore at all? Extirpated species? (They can never come back if all their habitat is completely destroyed for ever.) Are they still going to be tracked as species of provincial interest by MNR, as they are now? I continue to think it's ridiculous that any type of species at risk wouldn't be listed and/or doesn't have any protection measures. Why does it have to be a critical situation to do anything?

* Does the Minister have the discretion to review a registration and decide that it needs a permit, instead? If there isn't any oversight at all on the registrations, this is VERY dangerous and MECP could be at risk of not meeting it's responsibilities to the people of Ontario to have a framework that properly and measurably protects SARs. How are proponents informed in the first place about the species that may be impacted by their proposal?

* When you say, "killing a protected animal species (e.g., mammal, fish, reptile) if the activity is not already subject to an exception..." do you ONLY mean killing a mammal, fish, or reptile? Why are there any / why are these specific examples listed? What about birds, molluscs, insects and all the other types of animals and that are at risk of decline and extinction? What about killing of PLANTS?

*displacing a SAR out of its habitat (i.e., destroying the lands and resources it needs to live) should also require a permit.

*in summary, if a species is on the SAR list you establish (animal, fungus, plant, lichen... ), and individuals of that species are proposed to be killed, or elements of habitat are proposed to be removed, then a permit should be required.

* If there is a public registry (for the registrations), there must be a public venue for the permits, too. That would be this platform here: the ERO. There should be NO EXEMPTION for permits and orders (for all SAR plants and animals) issued under the SCA from Part II of the EBR. All environmentally significant decisions should be posted on the ERO. Anything to do with SARs is environmentally significant. Do not move forward with this exemption, please. This is a very trickily worded part of your proposal and it's a real shame that you were not transparent about what this part of your proposal actually means, practically, for those people reading this that don't know how to read legalese on e-laws. Does a 45 day proposal count as being consulted on if most people don't understand every part of the proposal?

Thanks for reading.