I am concerned that the…

I am concerned that the changes to Redside Dace habitat protection from 20 years to 10 years will allow for the species to more easily go undetected in habitat where it is present. If sampling permits are not granted, the species cannot effectively be found, but not finding a species when an agency is not permitted to sample should not be enough to claim a species is not present. There are reports that permits were not granted without reason, and this raises a question of a conflict of interest where the Ontario government wants to enable infrastructure construction and also oversees the agency responsible for permits. The denial of permits was brought up at the info webinar on January 30th, and also in The Narwhal's article, linked. The timeframe of 20 years should not be reduced until the species begins to recover.
At a time when Redside Dace is critically imperiled, it makes no sense to remove protections from former habitat, allowing further reduction of suitable habitat, instead of pursuing breeding programs and reintroducing the fish to recovery habitat, to help the species recover. Recovery habitat should not be reduced until the species begins to recover.

The changes to the way Butternut can be impacted does not make sense. If there is no waiting period before an assessed and registered butternut can be harmed, red flags in assessment cannot be caught and followed up on, and results of the BHA cannot be verified in the field. Additionally, it is unclear what the requirements are in the case of assessing a Category 3 butternut - are they required to allow time to collect scions before harming the tree?
Removing the waiting period is a senseless concession that makes it easier to conduct mediocre assessments in the favour of developers that cannot be adequately confirmed. 30 days is not long to wait, and BHAs must be completed during leaf-on, which coincides with the breeding bird window, when trees are not to be cut down without a nest sweep. Removing the waiting period does not aid in removal outside this active window.