It’s my opinion the proposed…

It’s my opinion the proposed changes would weaken the ability for the government, scientific community and people of Ontario, to actually protect SAR. Furthermore I do not think this is in alignment with the Federal Governments commitment to sustainable development.

Giving the Minister more freedom to make decisions without requiring the consultation of independent experts, to support social and economic development, reduces regulatory transparency and inhibits the voice of the scientific community. More comprehensive and credible decisions are made when feedback from independent experts is incorporated into decisions and made publicly available; It gives the public the ability to understand the impacts from a non-bias perspective. The proposed changes would impact the credibility of the information being provided to the public, therefore reducing their ability to provide meaningful feedback on projects. By removing that step, decisions will likely be short sighted and ineffective.

With regards to the criteria for the exemptions proposed, I think it is important to specify who is responsible for deciding if a project meets the criteria or not. It’s my opinion independent experts should be incorporated into this part of the process, to ensure regulatory transparency.

I also think there are many ethical flaws with the concept of letting corporations pay to kill SAR, and the tradeoff being the implementation of another new provincial agency to manage these transactions. The Province doesn’t need more agencies, it needs more Regulators focused on the intent of the Act, which is to protect SAR. Nothing about this proposal seems to genuinely support the goal of protecting SAR. I don’t think this is in Ontario’s long term best interest.