I am deeply concerned about…

ERO number

025-0380

Comment ID

127280

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

I am deeply concerned about the proposed changes to Ontario’s Endangered Species Act. These changes significantly threaten the protection and recovery of vulnerable species.

First, shifting to a registration-first system for permits undermines oversight and allows harm to occur before environmental assessments are conducted. This weakens the precautionary approach essential for protecting at-risk species and their habitats.

Second, allowing the government to override decisions made by COSSARO—an independent scientific body—threatens the integrity of the species-at-risk list. Giving the government discretion to decide which COSSARO-assessed species receive protection, and which don’t, removes objectivity from what must remain a science-based process.

Third, 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.

Lastly, the proposal to cease compiling recovery strategies and progress reviews where federal documents exist is a huge step backward. Removing a requirement for the development of recovery strategies and having no means to evaluate success of a species recovery reduces accountability, undermining 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 organisations 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.

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 should 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.

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 biodiversity.