I am writing to express my…

I am writing to express my concerns regarding the Ontario government's proposed replacement of the Endangered Species Act (ESA) with the new Species Conservation Act (SCA), as outlined in ERO #025-0380.

While I understand the government’s goal of reducing administrative delays and improving the efficiency of environmental approvals, I believe the proposed changes risk significantly weakening the protections currently in place for species at risk and their habitats.

Key Concerns:

1. Loss of Scientific Independence:
The current role of the Committee on the Status of Species at Risk in Ontario (COSSARO) ensures that species assessments are grounded in independent scientific research. Allowing discretionary power to delay or block listings undermines the objectivity of this process and could leave vulnerable species unprotected during critical periods.

2. Narrow Habitat Definition:
The proposed redefinition of habitat to focus only on specific dwelling places (e.g., dens, nests) fails to consider broader ecological requirements like foraging areas, migration corridors, and seasonal habitats, which are elements essential to species survival.

3. Elimination of Recovery Strategies:
Removing the legal requirement for recovery strategies and action plans diminishes long-term planning and accountability. Effective conservation requires a roadmap. These plans are vital to guiding meaningful recovery.

4. Registration-First Model Risks:
Allowing proponents to begin activities immediately upon registration, without permits or prior oversight, could result in irreversible damage to critical habitats. A permit-first model ensures that activities are properly evaluated and regulated before any harm occurs.

5. Lack of Indigenous Inclusion:
There is insufficient clarity on how Indigenous communities will be involved in species protection. Indigenous knowledge and leadership must be formally integrated into conservation planning, in accordance with reconciliation efforts and Treaty obligations.

Recommendations:

Maintain mandatory listing based on COSSARO assessments without political discretion.

Retain comprehensive definitions of habitat that reflect ecological realities.

Preserve the requirement for recovery strategies and habitat regulations for listed species.

Use a permit-first system to ensure rigorous review before activities are undertaken.

Formally integrate Indigenous perspectives and stewardship in conservation decisions.

Ontario has an international responsibility to safeguard its biodiversity. I respectfully urge the government to reconsider this proposal and ensure that any reforms strengthen, not weaken, the protection of species at risk.

Sincerely,
One of the many Proud Owners of Ontario