I have a number of concerns…

I have a number of concerns with this proposed legislation.

- It extends the time from when a species is classified as 'at risk' to when it becomes protected by the act, from 3 months to YEARS. Currently, an independent group of experts classifies species' at risk. Once classified in this way, the species becomes protected within 3 months. The proposal extends this time to 12 months, and allows the Ontario Minister of the environment to use his/her discretion to ask the group of experts to 'reconsider' their classification, effectively extending that 3 month period to multiple years. Not acceptable.

- It requires the group of experts to consider the status of a species OUTSIDE of Ontario, before classifying a species as at risk. This means that if a species is dying off in Ontario because we are destroying its habitat, but it is doing OK in, say, the Yukon, we will simply let this species become extinct in Ontario. Think about that - what would happen if every geography managed their species at risk in this way? Do we really want to let species like the Snapping Turtle die off in Ontario? Not acceptable!

- It allows the Minister of Environment to interfere in species protection. Here is one example of that in the proposal: "Remove the requirement for the Minister to consult with an independent expert in the ‘D’ permit process". There are several other examples. This is will effectively allow political and lobbying influences to dominate decisions, as opposed to scientific influences. I am already embarrassed at the extent to which our government goes to deny facts and silence its detractors; this bypassing of science-based regulation is not acceptable.

- It introduces a pay-to-proceed fee that allows developers to bypass protection activities that would otherwise be required. A direct quote from the proposal: "... allow municipalities or other infrastructure developers the option to pay a charge in lieu of completing certain on-the-ground activities required by the act". This speaks for itself. Money trumps all. Not in my books!