Please find attached (and…

Please find attached (and below in text) Ottawa Riverkeeper's comments on the proposed changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025, ERO: 025-0380

Ottawa Riverkeeper Comments on the Proposed Species Conservation Act, 2025

Ottawa Riverkeeper, a registered Canadian charity and leading voice for the ecological protection of the Ottawa River watershed, respectfully submits the following comments regarding the Government of Ontario’s proposal to repeal the Endangered Species Act, 2007 (ESA) and introduce the Species Conservation Act, 2025 (SCA).

We are deeply concerned that the proposed legislation significantly weakens Ontario’s framework for protecting species at risk. Our comments below outline key issues with the proposed changes and provide recommendations aimed at maintaining effective, science-based conservation.

1. Redefinition of “Habitat”

The SCA proposes a significantly narrower definition of “habitat,” limiting it to dens, nests, or immediate surroundings. This approach fails to account for the ecological reality that most species rely on diverse, interconnected habitats. Protecting only a tiny “core” patch around a den is insufficient for most wildlife needs.

This is particularly true of aquatic and semi-aquatic species that depend on entire watersheds and healthy ecosystems surrounding them. This change strips legal protection from migration corridors, foraging zones, and seasonal habitats critical to survival.

Restricting legal habitat protections in this manner will leave large portions of essential habitat unprotected and vulnerable to degradation. Furthermore, the removal of current “harassment” provisions and the elimination of mandatory recovery strategies further weaken habitat conservation and restoration efforts, fly in the face of ecological science, and weaken the very notion of protected habitat.

Recommendation: Retain a robust, ecosystem-based definition of habitat that reflects the full range of environments necessary for species survival and recovery.

2. Replacement of the Permit System with a Registration-Based Approach

The shift from a permit-based system to a registration-based model allows proponents to begin activities immediately after registration, without prior environmental review. This change removes opportunities for site-specific assessments, mitigation planning, and expert or community input. Removing the permit review phase means there is no opportunity for environmental authorities to assess site-specific impacts, require project redesign, or impose monitoring requirements in advance.

The absence of a formal review process undermines the precautionary principle, increasing the risk of irreversible harm to at-risk species and sensitive ecosystems. It also diminishes the role of Indigenous and public consultation. Protecting species and habitats requires collaboration with Indigenous stewards, not bypassing their rights. The government should ensure that any changes to species laws do not come at the expense of proper, culturally-appropriate consultation and consent processes.

Recommendation: Maintain a permit-based approval process for activities that may impact species at risk, ensuring proper review, accountability, consultation with Indigenous communities and Rights Holders, and stakeholder engagement.

3. Dissolution of the Species Conservation Action Agency (SCAA)

The proposal would eliminate the SCAA and redirect its dedicated funds into general revenue. The SCAA has served as an independent, transparent mechanism for supporting conservation activities when developers are unable to avoid impacts.

Abolishing the SCAA removes a valuable source of conservation funding and erodes long-term capacity for species recovery.

Recommendation: Preserve the SCAA or establish a similarly independent, dedicated fund to ensure continued investment in habitat restoration and recovery initiatives.

4. Elimination of Independent Advisory Oversight and Changes to Species Listing

The SCA removes the legal requirement for independent advisory bodies such as the Species at Risk Program Advisory Committee (SAR PAC), and grants the Minister discretionary authority over species listing, regardless of scientific recommendations from bodies like the Committee on the Status of Species at Risk in Ontario (COSSARO).

This centralization of decision-making undermines transparency and scientific integrity and risks further politicizing the listing and delisting process.

Recommendation: Reinstate and protect independent scientific advisory structures and maintain mandatory, science-based listing criteria for species at risk.

Conclusion

In summary, the changes would narrow habitat protection to only dwelling sites, remove recovery planning duties, transfer decision-making power from scientists to politicians, and allow projects to proceed with minimal oversight or Indigenous consultation, among other impacts. Each of these points independently erodes the integrity of at-risk species laws; together, they amount to a wholesale weakening of Ontario’s stewardship framework.

Ottawa Riverkeeper urges the Government of Ontario to maintain science-based listing criteria, robust, ecosystem-based definitions of habitat, independent advisory oversight, and a permit-based review system that allows for public, Indigenous, and expert input. Weakening these core protections threatens not only species at risk but the integrity of Ontario’s ecological legacy.