Comment
Pros:
• Maintains COSSARO’s Role:
• Science-based assessments for species status continue, which is a crucial safeguard to ensure listings are not purely politically motivated.
• Increased Funding:
• The proposed Species Conservation Program promises up to $20 million annually, over four times the previous funding, which could support more habitat restoration, research, and community-based conservation.
• Flexible Enforcement Tools:
• Stronger compliance and enforcement powers, including new compliance orders, could help prevent and penalize harmful actions more effectively—if they're properly applied.
• Focus on Habitat Restoration:
• The new program supports voluntary, on-the-ground conservation efforts, which can result in tangible habitat benefits.
• Clarification of Habitat Definitions:
• While narrower, the new definitions might reduce legal ambiguity, making it clearer when species protections apply—helping avoid loopholes and disputes if written carefully.
Cons:
• Shift to a Registration-First Model:
• Allows activities to begin immediately after registration, removing the wait for a permit review. This significantly reduces oversight and the ability to prevent harmful activities before they occur.
• Government Discretion Over Species Listings:
• Although COSSARO does the science, the government gets final say on whether species are protected, raising the risk of politicized decisions or delays in protection.
• Weakened Habitat Protections:
• New definitions of "habitat" are narrower and more focused only on breeding/rearing sites. This could leave critical foraging or migratory areas unprotected.
• No More Mandatory Recovery Plans:
• Removing the requirement for recovery strategies and response statements weakens accountability and long-term planning for species at risk.
• Elimination of “Harassment” as a Prohibited Activity:
• “Harass” covered a wide range of stress-inducing or harmful behavior toward species. Its removal narrows protections, possibly allowing harmful but non-lethal disruptions.
• Winding Down of the Species Conservation Action Agency:
• Ends a potentially important mechanism for targeted conservation funding, even if it was underused so far.
• Reduced Protections for Migratory Birds and Aquatic Species:
• By deferring to federal laws (SARA), Ontario relinquishes authority, potentially leaving gaps in enforcement and protection.
• No Guaranteed Public or Expert Oversight:
• Disbanding the Species at Risk Program Advisory Committee removes a formal advisory mechanism—less transparency and accountability.
Bottom Line (Environmental Lens):
While the bill includes increased funding and some modernization, it overall prioritizes development efficiency over environmental protection. It weakens mandatory protections and oversight, placing more trust in voluntary compliance and post-hoc enforcement. This could lead to more species decline if the system is not rigorously monitored and enforced.
In my opinion, the Cons outshine the Pros and this is something that needs to be addressed. This could allow for abuse and changes that cannot be undone.
Submitted April 22, 2025 9:36 PM
Comment on
Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025
ERO number
025-0380
Comment ID
126692
Commenting on behalf of
Comment status