Many of the proposed changes…

Many of the proposed changes essentially make the act useless for protecting endangered species. There may be ways to make it such that the process of evaluation is more streamlined, but what this act does is simply eliminate aspects that would allow species to be protected.
A few examples

1) "Require COSSARO to consider a species’ condition around its broader biologically relevant geographic area, inside and outside Ontario, before classifying a species as endangered or threatened. If the overall condition of risk to the species in the broader biologically relevant geographic area is lower, COSSARO would be required to adjust the species’ classification to reflect its overall condition"

This would exclude many edge of range species that are rare in Ontario, but might be common elsewhere. These species still play a role in Ontario's ecosystems and biodiversity, and are of value to Ontarians. The act should consider the species as they are in Ontario, not other jurisdictions. Furthermore, if every jurisdiction thought like this, it might encourage species to be eliminated because "well, they're more common somewhere else, so we don't need to protect". Ontario should not set that precedent, and should only consider the status of the species within our borders.

2) "Allow the Minister to require COSSARO to reconsider the classification of a species where the Minister forms the opinion based on scientific information that the classification may no longer be appropriate. For species that are not yet on the list or are listed as special concern, the proposed changes provide that the species would not be added to the SARO List or listed to a more endangered status during COSSARO's re-assessment."

Unless the minister has a background education in this field, this does not seem practical. It does not seem reasonable that one minister should be granted the equivalent scientific authority to a body of experts. It also opens up the possibility that the "opinion" of the one minister comes from selectively chosen science.

3) Section 2A
Protections should be automatic, regardless. The economic and social impacts of implementing them for endangered species will not be so vast that they require any reconsideration. Not to mentions that "applying the prohibitions to the species would likely have significant social or economic implications for all or parts of Ontario so additional time is required to determine the best approach to protect the species and its habitat" and "additional time is needed to address the primary threats to the species, or co-operation with other jurisdictions is necessary to reduce the primary threats to the species," seem contradictory. If more time is needed to assess the best protection measures, then the species should receive automatic protections to offset damage in the meantime, not have them delayed.

4) Creation of Regulatory Charge and Agency
Paying in lieu of conducting the required activities to offset harm does not help protect species, no matter what fund it goes into. Development will not stop, and if we want to preserve species on the landscape, we need to take measures to keep them there, not put money into a fund for unspecified conservation measured elsewhere.

5) "Broaden COSSARO member qualifications to include members who have relevant expertise in ecology, wildlife management, as well as those with community knowledge."
The first two fields of ecology an wildlife management are reasonable, but "community knowledge" is vague, and does not relate to expertise with respect to managing endangered species. While it is without a doubt some have an intimate understanding of the wildlife in a region, unless there is someway to verify the accuracy of that knowledge, it does not compare to the scientific expertise required to make assessments and recommendations for the management of endangered species.