Dear Premier Ford, and…

Dear Premier Ford, and Honorable Ministers,

I am writing in response to the proposed interim changes to the Endangered Species Act (ESA, 2007) and eventually transition into new the Species Conservation Act (SCA, 2025).

I agree growth is necessary for the economic and social well-being of the Province of Ontario. We need growth, to continue providing housing and employment opportunities for current and future Ontarians. We should promote growth that is sustainable. I work in the environmental consulting industry and understand this is necessary.

However, we cannot deregulate and take away protections, that harm long term environmental sustainability and survival of endangered species. The proposed interim changes to the ESA, take things too far, and reduce the effectiveness of this program.

The proposed definition change of "habitat" is too narrow, and takes away protections of endangered species, and opens the door for potential mismanagement. The new definition only includes nesting or denning areas, and doesn't include larger foraging, feeding, or mating areas. This essentially protects an animal's direct home, but not larger areas also needed for survival. Also, it can be interpreted as when an animal is no longer actively nesting or denning it is no longer habitat. As such, what is to stop someone from clearing Bobolinx habitat in the wintertime?

Likewise, the ESA changes weaken protections for federally listed species and is going to no longer going to protect federally listed migratory birds and aquatic species. Lack of protection of these species from the provincial government, will create gaps that the federal government may not be able to cover up and provide adequate protection. The partnership between the federal and provincial governments to protect endangered species as worked well in the past, why would you jeopardize that?

Also, proposed changes to the ESA, potentially breaks several laws and obligations from the federal government. For example, the Species at Risk Act (SARA, 2002) applies to federal lands, and provinces are expected to cooperate under Section 11 agreements. If Ontario fails to protect species on provincial lands, the federal government can intervene under the "safety net" provisions (Sections 34 & 61). As such, if Ontario fails to meet its requirements the federal government may intervene, this could have negative impacts that actually slow economic growth and cost the taxpayers more money.

Another example of this is the Migratory Birds Convention Act (MBCA, 1994). The MBCA protects migratory birds and their habitats in Canada, in cooperation with international treaties. The proposed ESA changes will remove Ontario-specific protections for migratory birds, assuming federal coverage is “enough.” However, habitat destruction permitted under Bill 5 could violate Section 5 of the MBCA, which prohibits disturbing, destroying, or taking migratory birds or their nests.

For the above reasons, I don't agree with the proposed interim changes to the ESA. I think the provincial government needs to rethink these changes and allow for more public consultation.

The provincial government lead by Premier Ford, has done an excellent job in standing up against Trump tariffs and trade war threats from the USA. Now it is time to stand up for the environment, and for the long-term health of Ontario! Our endangered species need protection, or their survival will be in jeopardy! We need to maintain the current ESA, or we risk losing or causing irreplaceable harm to our endangered species.

Please rethink the proposed changes and reevaluate to allow the ESA to do what it was designed to do, protect endangered species!

Thank you for your time.

Sincerely yours,

Alex