I am writing to express…

I am writing to express concerns regarding the proposed amendments to the Endangered Species Act.

1. The proposed change to the definition of "habitat" to dwellings and immediate surroundings, or critical root zone in the case of vascular plants, is far too narrow and discounts the broader environment that species requires for survival. Habitat loss and degradation are already one of the leading causes for the decline in biodiversity and species at risk. Narrowing the definition of "habitat" will do nothing but accelerate this decline.

2. The proposed changes that would eliminate the provincial responsibility for protecting migratory birds and aquatic species at risk that are also protected under federal legislation is irresponsible and will contribute to greater negative effects to those species. Provincial and federal governments need to work together in order to protect such wildlife, and lack of coordination will make protection even more difficult and allow things to fall through the cracks.

3. The registration-first approach is highly problematic as it will allow proponents to begin development activities immediately and without proper review. The permitting and review process allows environmental professionals time to assess the potential impacts of the proponent's action. This professional insight is highly important when it comes to protecting species. The proposed changes essentially eliminate this step and will lead to negative impacts to species in development areas that could have been avoided. There is nothing sustainable about this change and it will ultimately lead to an increase in irreversible, negative impacts to our species.

4. The removal of the requirement for the Ministry to prepare recovery plans and documents removes accountability for species protection. One species at risk is not more important than the rest, and all need actionable strategies for protection and recovery if we truly want to stop extinction.

I urge you to reconsider this bill and maintain strong environmental laws that prevent extinction and preserve Ontario’s natural heritage.

Thank you for your attention to this critical matter.