Comment
The proposed legislative changes pose a significant threat to the conservation of Ontario’s biodiversity. They prioritize economic development over ecological responsibility, weaken scientific and public oversight, and risk the loss of irreplaceable species and habitats. It is imperative that Ontario maintains strong, science-based protections for species at risk to ensure the health and resilience of its ecosystems for future generations.
1. Weakening of Scientific Oversight
The proposal grants the government discretion to add or remove species from the protected list, even if the Committee on the Status of Species at Risk in Ontario (COSSARO) has classified them as endangered or threatened. This undermines the role of independent scientific assessment in species protection, potentially allowing political or economic considerations to override ecological imperatives.
2. Shift from Permits to Registration
Transitioning to a registration-first approach for activities affecting species at risk diminishes rigorous environmental oversight. Under this model, proponents can commence activities immediately after registration, without prior review. This could lead to irreversible harm to species and their habitats before any mitigation measures are considered.
3. Narrowing of Habitat Definitions
The proposed redefinition of “habitat” to focus solely on specific dwelling places like dens or nests neglects the broader ecological requirements of species. Such a narrow definition fails to account for essential areas used for foraging, migration, or seasonal activities, thereby compromising comprehensive habitat protection.
4. Removal of “Harassment” Protections
Eliminating the term “harass” from species protections could permit activities that disturb or stress wildlife, leading to adverse effects on their health, reproduction, and survival. This change weakens safeguards that currently prevent disruptive human interactions with vulnerable species.
5. Potential for Increased Habitat Destruction
By streamlining approvals for development projects, the proposal may facilitate habitat destruction under the guise of economic growth. This approach risks prioritizing short-term economic gains over long-term ecological sustainability and the intrinsic value of Ontario’s natural heritage.
6. Undermining of Public and Indigenous Consultation
The expedited processes and reduced oversight may limit opportunities for public and Indigenous communities to engage in meaningful consultation on activities affecting species at risk. Inclusive and transparent decision-making is crucial for equitable and effective conservation efforts.
Submitted May 1, 2025 11:22 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
128496
Commenting on behalf of
Comment status