Although I'm in favour of…

Although I'm in favour of improving protection for species at risk it seems like this proposal is completely inadequate for doing so. Below I list 11 of the biggest problems with the proposal as written:

1. The overall direction of the ESA review is environmental deregulation.
The options under consideration appear to make it easier for industry and development proponents to damage or destroy the habitats of species that get in the way of business.

2. The options under consideration would undermine the very cornerstones of the law.
The “gold standard” requirements of the ESA - science-based listing of species at risk (including Indigenous Traditional Knowledge), mandatory protection of threatened and endangered species and their habitats, and legislated timelines for planning and reporting - are not something that should be altered because of their evidence-based nature.

3. The science-based process for listing species at risk is working so don[t try to "fix" it.
Though the ESA already allows the Minister to request a review of a listing decision on the basis of “credible scientific information,” you seem to be expanding on the basis of “conflicting information”

4. Protecting species at risk and their habitats should not be left up to the Minister.
Considering alternatives to automatic species and habitat protections, including removing or delaying these protections at the discretion of the Minister, would leave our most vulnerable plants and animals subject to political whims and the influence of powerful industrial lobbyists. This is definitely not the actions of a "government for the people".

5. You shouldn't weaken requirements for authorizations to undertake harmful activities.
Currently, industry and developers can proceed with harmful activities (e.g., killing members of threatened or endangered species, damaging or destroying their habitat) only if they have a permit or exemption. These authorizations should not be made less onerous so that they don’t stand in the way of economic development.

6. A “conservation fund” may replace on-the-ground reparation for permitted harmful activities.
Paying into a “conservation fund” may be the new easy-way-out for proponents of harmful activities. This option would make it easier and more likely for harmful activities to occur and will do nothing to protect our at-risk species and habitats.

7. There may be broad authorizations for harmful activities.
Landscape-scale authorizations for harmful activities may replace project-specific authorizations.This sweeping approach doesn’t lend itself to addressing site-specific or species-specific concerns and consequently presents unwarranted additional risk for species already in peril.

8. Poor implementation of the ESA is the problem, not the law itself.
According to the Environmental Commissioner of Ontario’s 2017 report, the government “has utterly failed to implement the law effectively.” Challenges should be addressed through improved planning and investment in communications, program development and staffing, not environmental deregulation.

9. Many of the more innovative aspects of the ESA have never been fully implemented.
These include stewardship agreements and ecosystem or multi-species approaches to recovery planning. Putting these tools into practice offers much more promise for species at risk than streamlining approaches to damaging and destroying their habitats.

10. Ontarians have a global responsibility to conserve biodiversity.
We are now in the throes of the largest mass extinction since the disappearance of the dinosaurs more than 65 million years ago. We must do our utmost to honour our collective responsibility, under the United Nations Convention on Biological Diversity, to maintain and restore the web of life.

11. The environment is a wholly owned subsidiary of the economy and this has to be recognized - without a healthy environment so many aspects of the economy will ultimately suffer!