It makes no ecological sense…

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

The list of species at risk must be determined by an independent scientific body; it must not be discretionary. Further, species that overlap with federal jurisdiction must not be removed from the provincial list; the province cites that this “removes duplication for species already receiving protections federally” but has not attested to the levels of protection currently afforded by the federal government. Further, approvals for habitat-destroying activities such as industrial resource extraction and development occur at the provincial level.

Further, this approach 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.

Clear conditions and binding requirements must be outlined prior to allowing developers and/or industry to merely 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 for project approvals and initiation must be integrated into law and policies that pertain to species recovery.