As on Ontarian, I cannot in…

As on Ontarian, I cannot in good faith support in any way the proposed changes to the ESA that our government has put forward.

It is unbelievable to me that these changes include stripping away the decision making rights of an independent committee, who is unbiased, objective and makes informed decisions based on careful consideration of the science available to deem the status of Ontario’s most vulnerable species. On the one hand, this government claims to want to reduce government influence and cut back “red tape”, while on the other hand takes away the process that ensures a non-government body makes unbiased, and non-political decisions for the fate of Ontario’s species at risk. This is contradictory and dangerous, not just for the species at risk and ecosystems that they influence and we as humans depend on, but also for Ontarians that value a just system not bound by an overbearing government making decisions for political agendas. It simultaneously strips away the process that protects our most vulnerable species, and strips away the freedom and voice of Ontarians who value a fair process where non-government voices can be valued and heard. What is there to say that more proposals to come to other acts, don’t include more changes like this that takes away the voice of unbiased independent parties, and puts the final decision making rights solely into the hands of the government? This is the opposite of what this government preaches. This also takes away the value of science, in 2025 I would hope we as a society understand how important informed decisions are that are back by objective science produced by scientists who followed a rigorous process to provide committees like COSSARO with the most accurate and unbiased information, to make the best decisions for our species at risk. Why does this government deem it appropriate to override science for the benefits of its political agendas and not what is best for both Ontarians and Ontario’s species at risk?
Secondly, to not just strip away the rights of COSSARO and advisory committees to determine the status of a species and oversee progress and make informed recommendations, but also not require there even be a recovery strategy for these species at risk is absurd. Why does this government think it is acceptable to acknowledge a species at risk and make no action plan to protect it? It’s a gross failure. Successful governments can gain economic advances while still ensuring the protection of our most valuable resources, ecosystems and species. In reality, these two things go hand and hand, there is no economy without healthy resources and many of our species at risk play vital roles in the functioning of these ecosystems that we rely on. It is unacceptable to not produce a recovery strategy for these species we recognize need protection.

To also redefine what “habitat” means to be just the dwelling of an animal and the immediate area surrounding that dwelling will be absolutely detrimental to any species who is migratory or requires a large home range to gain access to food and breeding opportunities for survival (the majority of our species at risk in Ontario). Consider the Eastern Wolf as an example, the population is now largely restricted to Algonquin Provincial Park (Benson et al., 2012) and is a threatened species. As the top predator in its ecosystem, it’s considered a keystone species, a species on which the health of the ecosystem relies on. They cannot be replaced by other species such as coyotes, and still have a functioning and healthy ecosystem because the two animals eat very different things and hunt with very different strategies (Benson et al., 2017). Large carnivores like this need large home ranges to consistently come across food (Hebblewhite & Whittington, 2020). In the case of Eastern Wolves their home range size is roughly 200 squared kilometers on average (the total space they need to occupy to meet their survival requirements). On top of this, one of their main prey sources are white tailed deer, who often migrate in the winter to deer yards for food (Benson et al., 2017). This already is posing a risk to the species, with human caused deaths being their biggest threat, and a very high death rate when they enter unprotected zones (either when they disperse to find mates, follow deer to unprotected areas to hunt or if all/ part of their home range falls in unprotected area), as it stands now the protections available for the long term survival of this species are already likely not enough (Benson et al., 2024). And yet, the proposed changes to the ESA would reduce the Eastern Wolf’s habitat and subsequent protection considerations, to only its den site (a site used only during pup rearing for mere months of its life each year), and not even consider its home range the habitat it relies on. This would detriment this species and it is just one example. Many other species that rely on larger areas to be protected to survive, such as migratory birds and Ontario’s multiple nearly extinct bat species that feed far away from their dwellings, would suffer from defining their habitat as solely the place where they dwell. On top of this, this proposal would allow for the harassment of these now even more vulnerable species. This is unacceptable. We as a province would fail our most vulnerable species if we allowed this, and as a result we’d allow ecosystems that depend on these species to collapse, something that would also negatively impact us as humans both physically and economically since we too rely on these ecosystems and resources to survive.

These changes are not acceptable and should never be allowed to advance. I sincerely hope this government rethinks these proposed changes, for the sake of our ecosystems and our people.