Dear MECP: It is not clear…

Dear MECP:
It is not clear how the enabling of the Species Conservation Act, 2025 with the proposed new amendments is going to improve efficiencies for project approval and allow for sustainable economic growth in light of the need to maintain environmental biodiversity, protect species at risk, protect and implement nature-based solutions and offer any chance of the Province achieving climate resilience. On the one hand, specifically, the wording in some of the amendments (e.g., Registration Regulation) are encouraging in that accountability and demands for conservation and mitigation planning and provisos can be imposed. Generally though, the amendments appear to simply represent performative efforts, basically a rejigging of the existing process. It is unclear how species protection concomitant with improving economic benefits are to be achieved differently with the SCA. Also, outstanding questions and arguments that have been the basis of actions seeking to repeal Bill 5, and the SCA transitioning from the ESA, still exist such as: definition of habitat for protection; designation of species at risk; recovery strategies for species at risk; meaningful First Nations consultation. See website references. It appears that registration and permit processing requires instead effective capacity management so efficiencies can be improved and projects moved forward expeditiously and conscientiously.
Thank-you for your consideration of these comments.
Ralph Baehre