I am deeply concerned by the…

I am deeply concerned by the proposed Species Conservation Act, 2025 and the risk it poses to vulnerable species in Ontario.

First, the proposed change to the definition of habitat is fundamentally flawed. Habitat is more than a den, nest, or plant root zone; it is the area that supports the all the environmental conditions an organism needs to survive. This definition must include finding food, water, shelter, and having sufficient space to carry out life functions such as establishing a territory, migrating, and finding a mate to reproduce, which are already accounted for in the existing Endangered Species Act. Just as the community that I live in as a human is more than my bedroom, and also includes where I obtain food (grocery stores and restaurants) and interact with other human beings (my workplace, park, library and other community spaces), a habitat must include both the resources and space for species to survive. Changing the definition of habitat critically threatens our ability to conserve spaces for species that are already in decline. The diversity of species is a biological heritage that once lost, can never be recovered. Healthy ecosystems and diverse species directly benefit the people of Ontario, by providing free ecosystem services (i.e. plants that produce clean air and filter water), financial benefits via eco-tourism, and quality of life benefits for Ontario residents; therefore, we should be doing everything in our power to strengthen, rather than undermine, protections for species in decline.

Second, the government of Ontario should not be able to remove protected species from the list of protected species. To do so would override the decision of the independent, science-based Committee on the Status of Species at Risk in Ontario, which, as an independent committee, is acting in the best interest of Ontario. Similarly, removing the Species at Risk Program Advisory Committee is also short-sighted, when this committee provides expert advice to the government in order to make informed decisions.

Third, the change to “recovery plans and documents” leaves endangered species without any support. Recovery strategies should be in effect before projects proceed, to ensure that a proposed plan is feasible and realistic. Likewise, the “registration-first approach” allows activities to begin before there is any oversight over their proposed changes. I firmly believe that an honour system is insufficient when there is a financial incentive for companies to pursue projects that may harm protected species; it is common sense that applications should be reviewed and approved before work may begin.

Finally, closing the Species at Risk Conservation Fund and removing the conservation charge undermines the ability for species in decline to recover. The current system creates ensures that there are dedicated funds available for restoration and recovery when those conducting harmful activities did not complete their own on-the-ground beneficial actions. Without this charge, there is no guarantee that the government would dedicate funds for species protection in the budget, which places declining species in a precarious position.

In conclusion, every almost aspect of the proposed Species Conservation Act, 2025 would place Ontario’s protected species at risk of decline and even extinction, which would cause irreversible harm to our natural heritage. I strongly oppose this bill, and encourage its immediate withdrawal.