I am in favour of updating…

I am in favour of updating legislation over time to take into account advances in human understanding, science, and changes in the world around us. Regarding this particular 'update' I have the following concerns/comments:
a. It makes no ecological sense to reduce the definition of “habitat” to mere immediate dwellings like dens, nesting sites or critical root zones. Species need large areas not just to sleep but to carry out their life processes like foraging, hunting and mating. If the government define humans' habitat as just their house, and not their larger neighbourhood or even broader area, humans would rightfully protest. We must use basic science to define the habitat on which all animals depend to survive.
b. The list of species at risk MUST be determined by an independent scientific body; it must not be discretionary. Future generations will judge harshly the ignorance of today's decision makers if they make decisions contrary to scientific evidence and cause irreversible destruction.
c. Further, species that overlap with federal jurisdiction must not be removed from the provincial list; the province cites that this “removes duplication for species already receiving protections federally” but has not attested to the levels of protection currently afforded by the federal government. Further, approvals for habitat-destroying activities such as industrial resource extraction and development occur at the provincial level. Further, this approach runs counter to the federal, provincial, territorial Accord for the Protection of Species at Risk, which stipulates a need for provinces to develop complementary species conservation initiatives. Revising legislation to make it more complication and less streamlined does not make sense.
d. Clear conditions and binding requirements must be outlined prior to allowing developers and/or industry to merely register their activities and proceed. History plainly shows that without these requirements, developers/industry WILL act first in a way that benefits them and ask for forgiveness later.
e. The elimination of recovery strategies makes it nearly impossible to effectively recover at-risk species. This does not make scientific sense and, again, is not an 'improvement' on this legislation - it is going backwards.
f. The commitment to obtain free, prior and informed consent for project approvals and initiation must be integrated into law and policies that pertain to species recovery. This should be an absolute requirement. Ontario must abide by UNDRIP and our commitments to Truth and Reconciliation. To simply ignore this is unconscionable. There are ways of integrating this requirement to create positive relationships and learning for everyone.