An updated legislative…

An updated legislative purpose that allows for decisions to be made in consideration of social and economic factors as well as species protection and conservation. COMMENT: these considerations are already made outside of the ESA, they dont need to be considered inside the ESA.
New definition of habitat that focuses protection only on the most critical areas needed by species.COMMENT: What? "most critical"? Species are endangered usually due to lack of habitat, it is very dangerous to try to determine what is "most critical" habitat.
Government discretion on whether to apply protections when a species is scientifically classified as extirpated, endangered, or threatened.COMMENT: leave the government (politics) out of this. Science and science only must be the decider.
Reduced duplication with federal legislation.COMMENT: Federal legislation is often more stringent and more in the endangered species interest. Dont weaken the process.
Expanded ability to conserve species through a new Species Conservation Program.COMMENT: this sounds too vague...like your crazy scheme to allow habitat to be "replaced"
A risk-based, proportionate, and progressive compliance model, aimed at collaboratively addressing potential violations, will support these changes. If harm to species occurs, the ministry has to tools to enforce the law and hold proponents to account. COMMENT: Perhaps the ministry does have the tools but it rarely uses them. This means the regulations are already pretty meaningless.
Establishment of a registration-first approach in place of the current permitting framework that will allow businesses to drive their own timelines for their projects based on clear, consistent rules. The online registry will have requirements established in a future regulation. COMMENT: You've got to be kidding. This sounds like "do what you like and we'll (maybe) ask questions later". Current permitting framework works better. It is not red tape..it is effective oversight in action.
Continued role of the Committee on the Status of Species at Risk in Ontario (COSSARO) in assessing and classifying species based on the best available science and information.COMMENT: I agree, but given the "discretion" you introduce above, the role of COSSARO would be weakened.