Good morning. I would like…

Good morning. I would like to draw attention to a logistical problem with the proposal pertaining to exemptions. See my comments below.

The proposal describes the following exemption:

"The proposed changes would provide the Minister with authority to temporarily suspend species and habitat protections for up to three years for some newly-listed species when the following specified criteria are met:"

By what expertise will the Minister assess whether the conditions are met? These criteria are entirely subjective and there are no checks and balances guiding the Minister's decision.

"1) applying the prohibitions to the species would likely have significant social or economic implications for all or parts of Ontario so additional time is required to determine the best approach to protect the species and its habitat;"

Losing or endangering a species is an invaluable loss and the ecological implications outweigh social / economic factors. That's why we have the concept of "endangered species:" to remember to prioritize them.

"2) the temporary suspension will not jeopardize the survival of the species in Ontario;"

If that were truly the case then that species would not be endangered. Can you name a single example where this exemption is logically consistent and sound?

"and 3) one of the following further criteria is met:
3a) the species has a broad distribution in the wild in Ontario;
3b) habitat availability is not a limiting factor for the species;
3c) additional time is needed to address the primary threats to the species, or co-operation with other jurisdictions is necessary to reduce the primary threats to the species,
3d) other criteria that may be specified by regulation."

There are major problems with 3c and 3d.
In the case of 3c, for any species that has already reached such a critical level of threat as to be listed as endangered, all protections to their habitat and ecological network must be implemented urgently. It's ignorant and ineffective to note that a species is endangered and wait three years before enforcing protections. Three years is several lifetimes or an entire generation for some species and this exemption will allow the Minister to delay protections, on a whim or due to pressures from biased parties, until it is far too late. As for criteria 3d, that point opens this proposal to all sorts of undemocratic, corruptions, unfounded activity. Any Minister with any level of interest can choose to create exemptions whenever and for whatever reason she chooses. That's irresponsible and destructive.

If this proposal goes forward you will lose much more than the respect and trust of your voters. I look forward to hearing that either several key changes have been made or that this absurd, in-useable, ill-advised and short-sighted proposal has been abandoned. Thank you for your consideration.