I am a member of the Toronto…

I am a member of the Toronto Entomology Association and as such I work with certain species of butterflies that are at risk or have been submitted to be listed. Consequently, I have a level of first-hand knowledge as well as a deep love for the natural world.
There are a number of very problematic and cognitively jarring issues with the proposed changes to legislation:
1) The reason that we HAVE endangered species is largely due to heedless development and extraction. Trees are being replanted because industry has not done so and habitat is being carefully restored because development has taken native habitat and replaced it will flora and fauna that is not native and causes harm to native species. Much of this happened before we realized the damage we were doing. WE DO NOT HAVE THAT EXCUSE ANYMORE. We, as a society are fully aware, or certainly should be, of the damage that we have done and the point of this legislation is to signal that industry and development must actually stop in certain cases, not that it should be given a license to continue damaging land or animals in return for paying financial compensation. Money cannot assist us here.

2) Science must be in the forefront of this legislation and consultation with the community (that would be people such as myself, an avocational entomologist who participates in citizen science, alongside actual scientists) that is informed on the subject, although important, should be in auxiliary to the facts.

3) changes to 'edge of range' definitions is particularly wrong-headed in light of quickly changing ranges in the era of climate change - in Ontario the ranges of birds are shifting dramatically every season. Breeding grounds are changing for multiple species. Plants are moving north. We cannot look to another location and site it as holding the majority range with any kind of assurance. Thus range is becoming a very poor indicator.

4) Ministerial 'discretion' is a political term that should not apply here at all, nor is it a responsibility that should be unfairly foisted onto a politician whose qualifications are not primarily science. We need stable, secure planning in order to protect Ontario's vast natural heritage and the political climate is never stable. The minister has enough responsibility without being put in the risky situation to act in a politically motivated fashion that is not in the best interest of our natural heritage.

5) There should be no approval available for industry or development projects that precludes ERO approval. This is a necessary safety check that must happen in order for honesty and integrity to prevail. Utilizing other laws as a 'back door' for approval damages our reputation as a society along with bringing almost certain harm to natural world.

6) We are in a time of climate emergency and a great extinction event, world-wide. Weakening the laws to protect native species of animals and plants that are under threat would be a tragedy that many, many citizens of Ontario will go to great lengths to avoid.