Comment
I just love birds, all birds, and the natural habitats they rely on. I spend as much time as I possibly can watching and photographing birds.
They are also important indicators of the health of the environment that everyone relies on for clean air and water, food and well-being.
As a biologist, I strongly believe Ontario MUST protect habitat for all migratory birds.
Alarmingly, I see no plan for such habitat protection in the proposed legislation and the new Species Conservation Program.
The latter will only protect the “dwelling place” or nest and very immediate vicinity of the nest but will NOT protect the forests, wetlands, grasslands and other habitats that are essential for survival of Ontario’s birds. This would be akin to providing a person with only a bedroom without also providing a kitchen for food, schools, hospitals, parks and other essential amenities. Just protecting the nest area itself does not protect the wider spaces birds need to find food, hide from predators or shelter from harsh weather.
The government’s rationale for the proposed changes is completely incorrect: Federal laws do NOT protect habitat for migratory birds on private or provincial crown land. It is up to the province to do that.
Therefore, at a bare minimum, legal protection for threatened and endangered birds should continue to exist for habitat on provincial crown land, just as the federal Species at Risk Act habitat protections apply to federal crown land.
Further, the existing habitat definition and protections of the Endangered Species Act should be retained. They provide a clear approach to conserving Ontario’s most at-risk birds; any issues of delays or lack of clarity can be dealt with through improvements in process.
Incentives for habitat protection on private land are necessary and must include funding for conservation easements and purchase of land by land trusts. The annual budget of the new Species Conservation Program must be sufficient to make this meaningful.
Ontario’s threatened and endangered birds absolutely require specific plans to ensure their survival and recovery. Disturbingly, the proposed changes eliminate the requirement to develop recovery plans and propose no meaningful alternative. Without recovery plans, the new Species Conservation Program will not be able to set priorities, and businesses and the public will not have guidance on the most important places to protect and actions to take.
Indigenous leadership, voices, knowledge, and ongoing work on the land are critical for wild birds to thrive in sustainable ecosystems. The proposed legislation must respect Indigenous rights and the duty to consult.
The changes as proposed let Ontario’s birds down. They undermine existing measures in place to protect birds and fail to replace these with effective alternative measures. There is NO acceptable justification for these irresponsible changes.
Submitted May 10, 2025 4:29 PM
Comment on
Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025
ERO number
025-0380
Comment ID
139045
Commenting on behalf of
Comment status