As an Ontario resident…

As an Ontario resident deeply concerned with environmental stewardship and biodiversity protection, I am writing to express my strong opposition to the proposed repeal of the Endangered Species Act, 2007 (ESA) and its replacement with the Species Conservation Act, 2025 (SCA) as outlined in ERO Notice 025-0380.

While I understand the government's stated goal of streamlining processes for development, I am alarmed that these changes significantly weaken the legal protections currently afforded to Ontario’s most vulnerable species. Specifically:

- Registration-First Approach: Allowing activities to proceed immediately after registration — without prior review — dramatically increases the risk of irreversible harm to species and habitats. This model prioritizes expedience over ecological integrity.

- Weakened Habitat Protections: The redefinition of "habitat" narrows the scope of protection and excludes broader ecosystems necessary for species survival. Effective conservation requires consideration of entire ecological networks, not just immediate nesting or rooting areas.

- Removal of the Term "Harass": Eliminating “harass” from legal protections ignores behavioral disturbances that can disrupt feeding, mating, and migration, which are scientifically recognized threats to species viability.

- Political Discretion Over Species Listing: Giving the government final discretion over which species are protected undermines the scientific rigor and independence of COSSARO. Conservation decisions must be based on evidence, not political or economic pressures.

- Elimination of Mandatory Recovery Strategies: Removing the legal requirement for recovery plans strips species of structured, science-based pathways to recovery. This could lead to fragmented and inconsistent conservation efforts.

- Wind-Down of the Species at Risk Conservation Fund: Ending this fund before a transparent and robust alternative is in place signals a deprioritization of long-term habitat protection and stewardship initiatives.

These proposed changes are not consistent with the Province’s duty to conserve biodiversity under both provincial and federal commitments. I urge the government to pause this legislative overhaul and engage in meaningful consultation with scientists, Indigenous communities, environmental organizations, and the broader public.

Ontario's endangered species deserve better. Economic growth must not come at the expense of irreversible ecological loss.