As an environmental…

As an environmental professional, I am writing to express serious concerns regarding the proposed amendments to the Endangered Species Act (ESA) and the introduction of the Species Conservation Act (SCA), 2025. While I support efforts to streamline regulatory processes and reduce duplication, the current proposal prioritizes development timelines over science-based species protection, weakening Ontario’s biodiversity safeguards at a time when environmental resilience is critically needed.

1. Undermining Science-Based Decision-Making

The continued role of COSSARO as an independent science-based advisory body is acknowledged, but the government’s proposed discretion to add or remove species from the Protected Species in Ontario List — regardless of COSSARO’s assessments — introduces the risk of politically motivated decisions. Scientific classification must remain the primary determinant of listing, without discretionary override. Any erosion of this principle compromises the objectivity and integrity of species-at-risk policy.

2. Registration-First Model and Loss of Oversight

Transitioning nearly all authorizations to a registration-first approach removes a vital checkpoint in the environmental review process. While the intent to reduce permitting timelines is understandable, allowing activities that may harm SAR or their habitat to proceed immediately after online registration—without prior review—greatly increases the risk of inadvertent non-compliance and irreversible ecological impacts. Proponents cannot be expected to self-assess complex species interactions or cumulative effects with the same rigour as trained ministry staff.

3. Habitat Definition Narrowing

The redefinition of “habitat” — particularly the removal of functional ecological components and broader habitat associations — disregards modern ecological principles. Limiting habitat to physical structures such as nests or dens, or to critical root zones, excludes essential areas used for foraging, migration corridors, staging, and shelter. These areas are often key to species survival and long-term viability. Simplifying habitat definitions for administrative clarity must not come at the expense of ecological realism.

4. Removal of Recovery Strategy and Planning Requirements

The removal of legislated requirements for recovery strategies, government response statements, and progress reviews represents a significant regression in Ontario’s commitment to structured, transparent, and accountable species recovery planning. Recovery documents provide not only guidance but also a record of intent and progress that stakeholders—including municipalities, developers, consultants, and Indigenous partners—rely on. Relying solely on discretionary guidance documents will reduce clarity, consistency, and effectiveness of conservation actions.

5. Deregulation of Federally Protected Species on Provincial Lands

While avoiding duplication is a valid concern, fully deferring provincial authority over aquatic and migratory bird species protected under the federal Species at Risk Act (SARA) could result in enforcement gaps—particularly in areas where federal resources are stretched or where federal-provincial coordination has been historically inconsistent. Retaining complementary provincial protections ensures stronger outcomes and local accountability.

6. Removal of “Harass” from Prohibitions

Eliminating the term “harass” from the list of prohibited activities may allow low-level but chronic disturbances—such as noise, artificial light, or repeated human presence—to go unregulated. These stressors have well-documented effects on reproductive success, survival, and site fidelity in many species. Protections should reflect contemporary ecological understanding, not just direct mortality.

7. Loss of Independent Oversight and Advisory Bodies

The proposal to dissolve the Species Conservation Action Agency and the Species at Risk Program Advisory Committee eliminates important independent and multi-stakeholder perspectives from the species protection process. These bodies provide transparency, accountability, and public trust. The shift toward centralized, internal decision-making—without formal advisory mechanisms—risks eroding public confidence and scientific credibility.

Conclusion

Ontario needs a system that enables timely development *and* upholds its duty to protect biodiversity. This proposal fails to achieve a balanced approach. A registration-first system without robust regulatory thresholds, narrowed habitat protections, removal of mandatory recovery planning, and discretionary listing powers significantly weakens species-at-risk protections.

I strongly urge the Ministry to:

- Retain COSSARO’s assessments as binding,
- Ensure discretionary listing/removal powers are transparent, evidence-based, and subject to public review,
- Maintain broader habitat definitions that reflect ecological reality,
- Preserve mandatory recovery planning and reporting requirements, and
- Provide independent oversight through advisory bodies.

Ontario’s environmental framework should not be dismantled in pursuit of expedience. We need reform, not deregulation.