It makes no sense to reduce…

It makes no sense to reduce the definition of “habitat” only to immediate dwellings like dens, nesting sites or critical root zones. Species need large areas, not just to sleep, but to carry out life processes like hunting, foraging and mating.

The list of species at risk must be determined by an independent scientific body; it must not be discretionary! Also, species that overlap with federal jurisdiction must not be removed from the provincial list! This proposed Bill runs counter to the federal-provincial-territorial Accord for the Protection of Species at Risk, which stipulates a need for provinces to develop complementary species conservation initiatives.

Further, approvals for habitat-destroying activities such as industrial resource extraction and development occur at the provincial, not federal, level. Clear conditions and binding requirements must be outlined prior to allowing developers and/or industry to register their activities and proceed.

The elimination of recovery strategies makes it nearly impossible to effectively recover at-risk species.

The commitment to obtain free, prior and informed consent from Indigenous Peoples for project approvals and initiation must be integrated into law and policies that pertain to species recovery.