Good day, It is agreed that…

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025-0380

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148032

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Individual

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Good day,

It is agreed that the "the process to obtain a permit is slow and complex" but the reason behind this is not cause for a dismantling of the protections afforded species at risk (SAR). The reason behind this is a legacy of cuts to environmental regulatory agencies that issue these permits. Not to mention the continual change of jurisdictions and upheaval that wasted tax-payer money switching regulatory agencies from the Ministry of Natural Resources and Forestry to the Ministry of the Environment, Conservation and Parks. How much money did that cost? Why?

It is clear that the Premier, and authors of this proposed Bill 5, have never actually gone through the permit process. The extensive delays, 8-10 months, is simply because it takes months to hear back from someone due to a lack of staffing. Hiring more permit reviewers is a much easier solution to this issue.

There is a time, place, and benefit to some of these permits. That said, it is agreed that there are some inefficiencies that could use consideration. Some of them are quite expensive, but that is the point. It is a disincentive for disregard of the environment. The registration process is a wonderful, streamlined approach and an expansion of that option is an excellent idea included in this Bill. That said, for the love of God, please update your system. It's glitchy, crashes regularly, has random rules that no one knows about just gives you random errors and is extremely old and needs an overhaul, especially if more people will be using it. That said, don't over-engineer it, just make what is there work easily. Enforcement will become more important. Which appears to be included in the act and will be required.

Again, a lack of experience shows with the idea to remove overlap with federal regulations. "Anyone carrying out an activity impacting these species on non-federal lands has been required to obtain authorizations under both federal and provincial species at risk legislation." This is not true, with provincial agencies often deferring to federal or working together for the same species considered.

The species conservation program, aka pay to slay, does need an overhaul. No concerns there.

The lack of oversight and accountability by winding down committees and the requirement for recovery strategies is short sighted. Without the research community-driven approach, how can decisions be made that are based on real data and science?

Please reconsider these sweeping changes in consideration of what has been stated above. Yes to enforcement and registration, no to lack of accountability and doing away with the Endangered Species Act in its entirety. And please add more staff to review permits in a timely manner and update your registration system.

Thank you.