Comment
The proposed overhaul of Ontario’s Endangered Species Act in favour of the Species Conservation Act, 2025 presents a fundamental risk to the survival of the province’s most vulnerable wildlife. While the government frames the reform as a “balanced” approach, it is, in fact, a clear and dangerous pivot from science-based conservation to industry-driven deregulation. The new registration-first model and government discretion over species protections weaken the very foundation of biodiversity protection in Ontario. This is not modernization — it is a rollback.
1. Deregulation Disguised as Efficiency
Allowing developers to proceed with potentially harmful activities immediately after self-registration — before any expert oversight — transforms environmental protection into a checkbox exercise. The elimination of mandatory recovery strategies, combined with a vague promise of future conservation guidance, removes the planning and accountability mechanisms that endangered species urgently need. Speed must not come at the cost of extinction.
2. Political Discretion Undermines Scientific Integrity
Under the current ESA, the classification of species at risk is legally binding once determined by the independent Committee on the Status of Species at Risk in Ontario (COSSARO). The proposed legislation would grant the government political discretion over which scientifically classified species receive legal protection. This introduces an unacceptable conflict of interest, opening the door to lobbying and political interference in decisions that should remain objective and evidence-based.
3. Redefining “Habitat” Leaves Species Homeless
The new, narrower definition of habitat strips away protections from the broader ecosystems that species rely on to survive. By focusing solely on dens, nests, or root zones, the legislation ignores foraging areas, migration routes, and ecological corridors — all essential components of viable species populations. Habitat fragmentation is a key driver of species decline, and this definition ensures it will continue unchecked.
4. “Voluntary Conservation” Is Not a Substitute for Legal Obligation
Replacing enforceable recovery strategies with a voluntary “Species Conservation Program” makes conservation optional, not mandatory. While additional funding is welcome, it cannot substitute for the robust legal protections currently embedded in the ESA. Voluntary actions, by definition, cannot be enforced or relied upon to deliver consistent, landscape-level results.
5. Erosion of Democratic Oversight and Public Participation
The elimination of advisory committees and the diminished role of expert input reduces transparency and erodes public trust. Ontario’s biodiversity is a shared heritage — decisions about its protection must be subject to independent scrutiny and inclusive consultation, not left to discretionary, behind-closed-doors decision-making.
Conclusion: A Reckless Gamble with Irreplaceable Biodiversity
These proposed changes are not a “balance”; they are a shift toward deregulation at the expense of our natural heritage. Ontario is one of the most biodiverse provinces in Canada, yet it is also one of the fastest losing species to habitat loss and climate change. This is the moment to strengthen — not gut — science-based environmental protections.
We urge the government to immediately halt the repeal of the ESA, maintain mandatory protections and recovery planning, and reject discretionary listing and registration-first development. Conservation must be law, not luck.
Supporting links
Submitted May 3, 2025 9:14 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
128955
Commenting on behalf of
Comment status