Overall Comments- This new…

Overall Comments-
This new proposed legislation will imperil our most vulnerable species and does not adequately address concerns regarding managing at-risk species. We are very concerned about the following:
• the very limited definition of ‘habitat’ when compared to the Endangered Species Act 2007;
• the discretionary listing of species, removing an independent and evidence based assessment approach;
• the offloading of responsibility for migratory birds and aquatic species to the federal government;
• the registration first approach; and,
• the elimination of recovery strategies, which makes it impossible to assess, mitigate and avoid harms to species.

Comments about individual components:
1. Protected Species in Ontario List Regulations
• This proposed regulation results in 106 fewer listed species in Ontario, including 64 species listed as special concern and 42 aquatic and migratory bird species listed under the federal Species at Risk Act.
• Recommend that the 64 species listed as special concern continue to be listed in the regulation and engage with the federal goverment regarding the 42 aquatic and migratory bird species that are now protected federally only to ensure protection and accountability

2 Registration
• we do not support the registration first approach as there is very little oversight; registration will not do anything to protect the species.

3 Permit Registration
• This proposed regulation concerning Permit Registration does not provide enough details for assessment. There is a need for a permitting process whereby enforceable terms and conditions are applied with significant limitations on when and how permits will be issued.