I am writing to comment on…

I am writing to comment on the proposed interim changes to the Endangered Species Act, 2007 and the proposal for the Species Conservation Act, 2025

I understand the need for streamlining of processes and speeding up permissions for important projects at the provincial scale.

However, as an ecologist of 35 years with a PhD in ecology, I have strong concerns about the proposed wording that affects the science of determining species at risk and their habitat. Species at risk are at risk often due to habitat loss. Determining what species are at risk should not be a political decision. We have a scientific agency that determines this. A species can only survive if its entire habitat is protected, not the narrow interpretation of the new proposed wording.
I recommend that a scientific approach be maintained to identifying a species at risk and to identify its habitat. For example, the endangered plant ginseng cannot survive by just protecting its critical root zone, it requires a shady forest interior to survive. Keeping the science in the Act while allowing for improved efficiency in its application would ensure the best protection for Ontario’s biodiversity for current and future generations.