I am writing to express…

I am writing to express strong opposition to the proposed interim changes to the Endangered Species Act, 2007 and the proposed Species Conservation Act, 2025 (ERO #019-8497). These changes would significantly weaken protections for Ontario’s species at risk.

As a conservation professional working in invasive species and ecological monitoring, I am alarmed by several aspects of the proposal:

• Narrowed habitat protections: Redefining "habitat" to exclude vital areas used for migration, feeding, and reproduction undermines species recovery and contradicts ecological science.

• Ministerial discretion over listings: Allowing political discretion in the species listing process threatens the integrity of scientific assessments and risks delaying urgent protections.

• Pay-to-proceed framework: Permitting developers to pay into a fund instead of mitigating direct impacts encourages habitat loss and weakens conservation accountability.

• Reduced protections for specific species: The proposals would ease development restrictions for species like Redside Dace and Butternut, jeopardizing already vulnerable populations.

• Erosion of Indigenous rights: Fast-tracking development in economic zones without full Indigenous consultation violates the duty to consult and undermines reconciliation.

Creating a parallel Species Conservation Act introduces regulatory fragmentation and prioritizes administrative flexibility over biodiversity protection. Ontario should focus on enforcing and resourcing the existing ESA, not replacing it with weaker alternatives.

Thank you for the opportunity to comment.