There are so many aspects of…

There are so many aspects of this proposal that are extremely detrimental to environmental and conservation work in Ontario. The Recovery Plans and Documents section of the proposal fails to acknowledge the importance of the review process for species listing. Not only are recovery plans and evidence important for transparency, but these plans also highlight long-term conservation efforts and accountability for aiding in the recovery of species. Conservation does not happen in a day, and there must be evidence of the proper steps and due diligence that must be taken to ensure a species has the best chance of recovery. This action: "The proposed amendments to the ESA would remove the requirements to develop recovery strategies and management plans, government response statements, and reviews of progress from legislation." obliterates all accountability and evidence of due diligence being done in the name of conservation and transparency. The proposal's outline of a "New Species Conservation program" is also concerning. No clear or long-term plan is outlined that instils confidence in future conservation efforts, with barely a promise of funding. The encouragement of "voluntary activities" means that developers will face no accountability for environmental destruction unless they deem remediation fit, let alone ensuring proper action is taken to mitigate damage. For example, offsetting by planting trees in an unrelated lot when a wetland is being drained for a project is not effective in terms of economics and environmental response. This proposal outlines a model of "better to beg forgiveness than ask for permission". The section regarding "duplication" between provincial and federal acts ignores the transient nature of migratory birds and aquatic species. These species are not static, and they do not adhere to borders, therefore, they are beyond just Ontario and its consideration. The effects of development are not static either, and it will have lasting effects beyond the immediate area, paving the way for habitat fragmentation and degradation, as well as water and air pollution. "Redefining protections" creates a narrow definition of habitat that refuses to take into account the physical and genetic movement of species. This definition does not take into account the continuous nature of habitats, instead creating small, unlivable spaces with hard separations. This concept can easily be summarised by edge effects created in fragmented habitats. Although a patch of habitat may seem large, the exposed edges of these patches become micro-habitats with differing temperature/precipitation conditions, therefore impacting the species that can exist within the edge. The actual usable habitat is much smaller than it appears. Similarly, the changes to the habitat definitions appear larger than they are, but have little consideration for the species involved. One of the most egregious changes is this: "... the government would have discretion to add extirpated, endangered, and threatened species to the list of protected species. The government would also have discretion to remove protected species from the list." The government should NOT have the power to remove protected species to fit their financial and developmental goals. There are many reasons why the listing process is extensively researched, planned, proposed, presented, and discussed, often by an independent committee and with transparency and input from the public and Indigenous stewardship. Although this process is not perfect, it's guaranteed that there is NO impartial decision where the provincial government is concerned for species at risk and environmental protection. The developers and money will win every single time. Removing protected species as the government deems fit will ensure their extinction and/or extirpation. Also, this proposal lacks a section purposefully and meaningfully detailing consultation with Indigenous stewardship. This is an extreme oversight for a proposal centring on environmental issues and species at risk. A lack of public input, especially with Indigenous groups, shows an extreme lack of accountability by the provincial government. I found the "Purpose" section of this proposal to be very interesting, highlighting a need for balance between conservation, alongside economic and social considerations. I believe this proposal worsens the interplay between these considerations and fails to meaningfully address them. Many aspects of due diligence and consultation are removed from the process, disgracing the vital social aspect of environmental protection. The economic considerations will continue to benefit the few, already wealthy individuals in the short term, while greatly impacting the long-term ecosystem services the environment provides and costing more down the line. I've included many descriptions of what a disaster this would be for the environment and conservation efforts. In no way is this proposal sustainable.