Subject: Opposition to…

Subject: Opposition to Proposed Changes to the Endangered Species Act, 2007 (ERO Number 025-0380)

Dear Ministry of the Environment, Conservation and Parks,

I am writing to express my strong opposition to the proposed changes to the Endangered Species Act, 2007, and the introduction of the Species Conservation Act, 2025, as outlined in ERO Number 025-0380. While I understand the need for economic growth and development, I believe these changes significantly undermine the protection of species at risk in Ontario.

1. Registration-First Approach: The shift to a registration-first approach for species-related authorizations is deeply concerning. This method allows activities to commence immediately after registration, potentially bypassing thorough initial assessments. This could lead to irreversible harm to species and their habitats before any meaningful review or mitigation measures are implemented. The current permit system, although slower, ensures that activities are carefully evaluated for their impact on species at risk.

2. Faster Project Timelines: While reducing delays and costs for housing, transit, and infrastructure projects is important, it should not come at the expense of our natural heritage. The proposed changes prioritize economic growth over the rigorous protection of endangered species. The existing process, though lengthy, is designed to ensure that development does not compromise the survival of vulnerable species. Just because a process is lengthy doesn't mean it's inherently bad; thoroughness is essential to avoid the pitfalls of half-baked, expedited decisions that can lead to significant errors.

3. Species Conservation Program: The introduction of a new Species Conservation Program to support voluntary initiatives like habitat restoration is a positive step. However, relying on voluntary measures is insufficient. Mandatory protections and enforced regulations are necessary to ensure that species at risk receive the protection they need. Voluntary programs cannot replace the robust legal framework currently in place.

4. Enhanced Enforcement: Strengthening enforcement capabilities is essential, but it must be coupled with stringent regulations and thorough assessments. The proposed changes suggest a weakening of initial protections, which could lead to increased non-compliance and harm to species. Effective enforcement is only possible when the underlying regulations are strong and comprehensive.

In conclusion, while the goal of balancing species protection with economic development is commendable, the proposed changes to the Endangered Species Act, 2007, and the introduction of the Species Conservation Act, 2025, do not achieve this balance. Instead, they risk prioritizing short-term economic gains over the long-term health and survival of Ontario's species at risk. I urge the Ministry to reconsider these changes and to maintain robust protections for our ecological heritage.

Thank you for considering my comments.

Sincerely,
KP