To Whom It May Concern, I am…

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025-0380

Comment ID

145594

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Individual

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Comment

To Whom It May Concern,

I am writing to express my strong opposition to the proposed interim changes to the Endangered Species Act, 2007 (ESA) and the Species Conservation Act, 2025 (SCA) as outlined in the Protect Ontario by Unleashing our Economy Act, 2025. While I understand the desire to support economic development, these proposed changes risk severely undermining the protections in place for Ontario’s species at risk.

The shift to a registration-first approach, which allows most activities to proceed as soon as they are registered, raises serious concerns. This could lead to harmful activities affecting protected species without thorough environmental assessments. Streamlining the process for development projects should not come at the cost of the careful, science-based evaluations that are essential for protecting biodiversity. A faster timeline for developers may reduce the scrutiny needed to avoid irreversible harm to species and habitats.

The proposed changes also give the government discretionary power to add or remove species from the Protected Species in Ontario List, which could open the door to political interference, putting species at even greater risk. Removing species from the list could reduce the level of legal protection they receive, undermining efforts to conserve vulnerable populations.

Furthermore, the redefined habitat protections could limit the scope of habitat preservation, potentially leaving out critical areas that species depend on for survival. The removal of "harassment" from species protections is also concerning, as it weakens safeguards against human activities that may harm species without directly killing them.

Eliminating the requirement for recovery strategies, management plans, and government response statements will limit the government's ability to address species conservation in a systematic, long-term way. These documents are essential for guiding recovery efforts and ensuring that species’ needs are met.

Additionally, I am concerned about the removal of key advisory bodies such as the Species at Risk Program Advisory Committee, which provided valuable input from environmental organizations, Indigenous communities, and other stakeholders. Reducing consultation opportunities limits the ability of these groups to shape conservation strategies and diminishes the transparency of the decision-making process.

While the creation of a new Species Conservation Program is a step in the right direction, it does not compensate for the loss of crucial protections. The wind-down of the Species Conservation Action Agency (SCAA) and the Species at Risk Conservation Fund will also result in the loss of critical funding that directly supports species protection and recovery initiatives.

Ultimately, the proposed changes threaten to erode the effectiveness of Ontario's species protection laws. I urge the Ministry to reconsider these amendments and ensure that future decisions prioritize the health of our ecosystems and the species that depend on them. Economic growth and conservation must go hand in hand, and this proposed legislation fails to strike that balance.

Thank you for your consideration.