Strong Opposition to…

Strong Opposition to Proposed Changes to the Endangered Species Act (ERO 025-0380)

I am writing to express my deep concern and strong opposition to the proposed changes to Ontario’s Endangered Species Act (ESA) outlined in ERO 025-0380. These amendments represent a significant rollback of critical protections for species at risk and their habitats, prioritizing short-term economic interests over long-term ecological sustainability.

Key Concerns:

Erosion of Habitat Protections: The proposed redefinition of "habitat" to include only immediate nesting or denning sites severely undermines the survival of species that rely on broader ecosystems. For instance, the redside dace, an endangered fish species, would lose protection in areas it historically occupied, jeopardizing its recovery efforts .

Shift to Registration-First Approach: Allowing proponents to commence activities immediately after registration, without prior review, increases the risk of irreversible harm to species and habitats. This approach diminishes the precautionary principle that is fundamental to effective environmental protection .

Government Discretion Over Species Listing: Granting the government authority to add or remove species from the protected list, even against scientific recommendations, politicizes conservation efforts and undermines the integrity of the Committee on the Status of Species at Risk in Ontario.

Removal of Recovery Strategies: Eliminating the requirement to develop recovery strategies for at-risk species neglects the proactive measures necessary for their conservation and increases the likelihood of extinction .

Introduction of the "Pay-to-Slay" Model: Allowing developers to pay into a fund in lieu of complying with ESA regulations fails to ensure the protection of species and their habitats. Monetary compensation cannot replace the ecological functions lost through habitat destruction .

Ontario is home to over 230 species at risk, many of which are already facing significant threats from habitat loss, climate change, and human activities. The proposed changes to the ESA will exacerbate these threats, leading to further declines in biodiversity. I urge the government to reconsider these amendments and instead strengthen the ESA to ensure robust, science-based protections for our province's vulnerable species and ecosystems.

Protecting biodiversity is not an impediment to development; it is essential for the health, well-being, and prosperity of current and future generations.