The proposed changes to…

ERO number

025-0380

Comment ID

135332

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Individual

Comment status

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Comment

The proposed changes to Ontario’s endangered species laws represent a significant shift away from science-based, preventative conservation toward a more industry-friendly, reactive model. At the heart of the plan is a move from permit-based approvals to a registration-first system, allowing developers and project proponents to proceed with activities immediately after registering online. While this may speed up timelines, it removes a crucial layer of oversight designed to catch potential harms before they happen. By letting projects start without prior review, the province is relying too heavily on after-the-fact enforcement, which is often too late to prevent damage to species and their habitats.

Equally troubling is the increased discretion the government is giving itself to decide which species are protected. Although the scientific body COSSARO will continue assessing species risk levels, the government will have the power to add or remove species from the protected list regardless of scientific recommendations. This opens the door to politically motivated decisions that could leave at-risk species unprotected due to economic or development pressures.

The proposal also narrows the legal definition of habitat, focusing only on specific features like nests, dens, or root zones. This approach disregards the broader ecosystems many species rely on, such as migratory corridors and feeding areas. As a result, essential habitat may be left unprotected, undermining the long-term survival of many species.

Another major concern is the removal of requirements to create recovery strategies and track conservation progress. These are foundational elements of effective species protection, and eliminating them significantly reduces transparency, accountability, and long-term planning. Without legally required recovery plans, there is no consistent roadmap for helping species recover once they are listed.

In winding down advisory committees and the Species Conservation Action Agency, the government is cutting out expert input and independent oversight. This move concentrates decision-making within the ministry and removes formal mechanisms for outside voices to influence conservation policy. Such a top-down approach risks weakening public trust and reducing the quality of decisions made.

While streamlining regulatory processes and avoiding duplication with federal laws are reasonable goals, the government’s approach tilts too far toward deregulation. Removing provincial oversight of aquatic and migratory species, simply because they are also federally protected, assumes federal authorities are fully equipped to manage these responsibilities alone — an assumption not always supported by evidence.

Finally, although expanding funding for voluntary conservation efforts is a welcome step, these programs cannot replace strong, mandatory protections. Voluntary action often lacks the consistency and coverage needed to address the urgent challenges many species face. Overall, the proposed changes prioritize economic development over ecological responsibility and place too much faith in compliance without oversight, voluntary actions without enforcement, and government discretion without public accountability.

It is historically evidenced that private companies cannot be trusted to do the responsible, right thing — frequently despite their own set mandates. This is what the government is for. This is what the so called "red tape" is for.