Comment
I am deeply concerned by the proposed changes to Ontario’s Endangered Species Act. These changes significantly threaten the protection and recovery of vulnerable species.
Shifting to a registration-first system for permits undermines oversight while allowing harm to occur before environmental assessments can be conducted. This weakens the precautionary approach essential for protecting at-risk species and their habitats.
In addition, allowing the government to override decisions made by the independent scientific body COSSARO threatens the very integrity of the species-at-risk list. Giving a government discretion to decide which COSSARO-assessed species receive protection, and which don’t, removes current and future objectivity from what should remain a science-based process.
Narrowing the definition of “habitat” will remove protections and exclude vital areas needed for species recovery, further endangering wildlife that is already at risk due to habitat loss and fragmentation. While I agree that the definition of habitat lacks clarity, narrowing it in this way would leave many of our vulnerable species to slip through the gaps.
The proposal to cease compiling recovery strategies and progress reviews where federal documents exist does not take into account Ontario's unique landscapes. As well, removing the requirement for the development of recovery strategies and having no means to evaluate the success of a species recovery reduces accountability, and undermines the Act by providing no path forward for conservation of a species. In addition, removing the function of formal advisory committees leaves a gap, and limits the province's ability to collaborate with organizations promoting conservation efforts. Instead, the government could focus on filling knowledge gaps by investing in research to support developing protocols for detecting species, determining critical habitat, and identifying opportunities for beneficial actions.
In conclusion, I strongly support the need for the government to maintain automatic legal protection for all species classified by COSSARO as extirpated, endangered, or threatened, to ensure decisions remain grounded in science. Permit-based oversight needs to be retained for activities that pose moderate to high risks to species or their habitats, rather than relying solely on a registration system. The proposed definition of habitat should be expanded to reflect the full ecological needs of species, including foraging, dispersal, and seasonal use areas. I also urge the government to preserve a legislated recovery planning process to provide a clear, coordinated path for species recovery. Finally, dedicated and transparent funding should be sustained, along with mechanisms for expert and stakeholder input, to support meaningful, collaborative conservation outcomes.
I want to add that along with our responsibility to protect our unique wildlife for future generations, any species can be a boon to medical research or provide pathways to new technologies and give Ontario a unique economic advantage. For example, in recent years research into snake venom compounds from different species has provided pathways to exciting therapies to treat cardiovascular diseases, offer pain relief, and even combat cancer. One of Ontario's most vulnerable species, the Blanding's Turtle (Emydoidea blandingii), is an interest to science for it's apparent lack of any signs of aging. Display screen advancements are copying the microscopic structure of butterfly wings, particularly the Blue Morpho. To lose any species is to lose a wealth of knowledge.
Streamlining the system should not mean weakening species protection. I urge the government to ensure that any new legislation remains grounded in science, transparency, and a strong commitment to Ontario’s unique biodiversity.
Submitted April 23, 2025 1:48 AM
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
126708
Commenting on behalf of
Comment status