I am submitting this comment…

I am submitting this comment in opposition to the proposed interim amendments to the Endangered Species Act, 2007 (ESA) and the legislative introduction of the Species Conservation Act, 2025 (SCA). The proposed changes represent a fundamental departure from evidence-based, science-driven conservation policy and significantly erode the statutory obligations Ontario has to species at risk under both domestic and international commitments (e.g., the Convention on Biological Diversity).

The ESA currently mandates timely species assessments, automatic habitat protection, and science-led recovery strategies. The proposed changes appear to introduce delays in listing species, enable discretionary exemptions for economic development, and reduce enforceable protections for critical habitat. These shifts contravene core conservation principles and elevate ministerial discretion at the expense of ecological integrity and scientific independence.

Moreover, replacing the ESA with the SCA—if it lacks binding timelines, habitat protection requirements, or enforcement mechanisms—would weaken accountability, fragment conservation efforts, and undermine public trust in environmental governance. The proposed framework does not align with best practices in endangered species recovery as outlined by the IUCN, nor does it adequately incorporate Indigenous knowledge systems and stewardship roles.

Ontario must not regress on species protection. I urge the government to withdraw these proposals and instead invest in the full implementation and enforcement of the existing ESA, while strengthening interagency coordination, habitat connectivity planning, and funding for recovery actions.