I am very concerned about…

I am very concerned about proposed changes to ESA. It seems to me that the main theme of the changes is that Ontario government wants to give too much decision making responsibility to the minister. Ministers typically do not have a background or understanding of ecology and therefore will have difficulty making decisions that truly benefit the species. Furthermore ministers are changed frequently through cabinet shuffles and therefore I fear new species will not get listed when a new minister is trying to get 'up to speed' with their new portfolio. The extra timelines and ministerial discretion will mean that there will be considerable delays in species listings, habitat protections and recovery strategies. Some specific comments:
1A - minister should have no more than 6 months to make listings public.
1E - a species status in jurisdictions outside of Ontario should not overide their status here. If species is legitimately at serious risk in Ontario, it should receive protection here, irrespective.
1F - someone with community knowledge but limited understanding of species or ecological principles should not be accepted into COSSARO. Appropriate expertise is needed.
2A - 3 years is much too long to suspend habitat protection, species may go extinct with such lagged timelines
2A iii (4) - "other criteria" this caveat leaves it too wide open. New species may never receive protection with such an open ended clause.
3 - allowing minister to significantly extend the timing requirements and relegating recovery strategies as merely "advice to government" will likely not give sufficient protection to species.
4 - Permits. This sounds like developers and municipalities will be able to get out of having to protect species or even need to complete necessary studies by paying into a conservation fund.

Ontario has an exemplary Endangered Species Act, that although not perfect, is offering a lot of protection to species and has slowed down the decline of many listed species. I fear that the proposed changes will water it down too much and provide many loopholes that will make the Act largely ineffective.