To Whom It May Concern, I am…

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 introduction of the Species Conservation Act, 2025 (SCA) as outlined in ERO notice 025-0380.

Ontario’s biodiversity is under increasing pressure from habitat loss, climate change, and human activity. Now more than ever, strong, science-based legislation is required to protect endangered species and their habitats. Unfortunately, the proposed legislative amendments move in the opposite direction. I respectfully urge the Ontario government to withdraw these proposals for the following reasons:

⸻

1. Undermining Science-Based Decision-Making

The proposal allows discretionary government authority over the listing of species at risk, weakening the vital role of the Committee on the Status of Species at Risk in Ontario (COSSARO). This change risks politicizing a process that should remain grounded in independent, scientific evidence.

⸻

2. Weakening Habitat Protections

The redefinition of “habitat” and the removal of the prohibition against “harassment” represent a significant step backward. Such changes could open the door to increased disturbance and degradation of critical habitats, especially when species are most vulnerable.

⸻

3. Shifting Toward Deregulation via the Registration-First Model

The registration-first approach proposed under the SCA enables development activities to proceed immediately upon registration. This shift greatly reduces oversight and could lead to non-compliance and unmonitored harm to species and ecosystems. It puts the burden of enforcement on an already strained system and reduces accountability.

⸻

4. Introducing Vague Economic Prioritization

Altering the purpose of the ESA to explicitly incorporate social and economic considerations undermines the act’s core goal: to protect endangered and threatened species from extinction. Conservation laws must prioritize ecological integrity, not economic convenience. Sustainable development must work within the bounds of environmental protection, not override it.

⸻

5. Insufficient Public and Indigenous Consultation

There has been insufficient time and consultation with the public and Indigenous communities regarding these sweeping changes. Indigenous nations hold unique relationships with the land and species and must be meaningfully engaged in co-developing policies affecting biodiversity.

⸻

Conclusion

Ontario’s endangered species and the ecosystems they depend on need more protection, not less. The proposed changes compromise the province’s environmental leadership and responsibility to future generations. I urge the government to:
• Withdraw the proposed changes to the Endangered Species Act, 2007;
• Abandon the proposed Species Conservation Act, 2025 in its current form;
• Commit to a transparent, science-based, and inclusive review process;
• Strengthen—not weaken—Ontario’s commitment to biodiversity.

Thank you for considering this submission.

Sincerely,
Katy