I have significant concerns…

I have significant concerns respecting the proposed regulations implementing the Species Conservation Act. Measures to protect species at risk should not be considered 'red tape' that get in the way of economic development. Instead, the government should give heed to some of the last words of the late Jane Goodall that "we are all part of Mother Nature". The fact that humankind is having a devastating diminishment of the rich biodiversity of our natural system should not be lost in the current haste to push for new economic development at all costs.

The need to protect critical habitat for species at risk should not be reduced as is proposed by the legislation. Buffer areas are required to support the function and future potential of species to thrive. The government should put in place requirements that protect, conserve and and assist in the restoration of imperiled species (see requirements for natural heritage protections outlined in the Provincial Policy Statement).

The list of risk species should be established by professionals in the ecological scientific field. The proposed legislation does a disservice to science by permitting species identification to be set by politicians and their political whims.

Species at risk do not distinguish between differing political jurisdictions - federal versus provincial. Differing regulatory processes and requirements are found at the federal and provincial levels for protecting species at risk that cross boundaries. The province should show clear leadership in listing species at risk that are identified by scientific consensus at either the federal or provincial levels. This is a clear display of information provision for all development proponents.

The precautionary principle to identifying and protecting species at risk should not be abandoned as per the proposal to 'give notice' and then 'do development'. In too many instances premature development activities have advertently or inadvertently done harm to species at risk. A permit system to conduct preemptive development is not a wise proposition.

Finally, the legislation is not appropriate in not advancing recovery mechanisms for species at risk. If the Act's intent is to 'conserve' species at risk then tools need to be outlined as to how this can be accomplished in acts of development. This is a significant shortcoming in the proposed legislation. Additional attention should be prescribed by the government to protect and conserve species at risk.

As we all know, both human and natural communities are dependent upon a healthy diverse ecosystem for long term resiliency and continued livability. The proposed legislation has many shortcomings that will perpetuate damage to 'Mother Earth'; it should be withdrawn or rewritten to address the above noted issues.