Comment
Firstly, the current Endangered Species Act defines habitat as, “an area on which the species depends, directly or indirectly, to carry on its life processes, including life processes such as reproduction, rearing, hibernation, migration or feeding.” The new Species Conservation Act defines animal habitat as “a dwelling place or the area immediately around it, such as a den, nest or other similar place, that is occupied or habitually occupied by one or more members of a species for the purposes of breeding, rearing, staging, wintering or hibernating.” It also includes the area immediately around a dwelling place that is essential for the purposes set out in that subclause. This change means that other processes critical to species survival – like finding food- are no longer protected. How does the government propose that species will be protected if only parts of thier habitat are protected. Can you survive if you can live in your house, but can't go to the grocery store?
Secondly, the shift to a registration first approach for nearly all species related authorizations. Under this new system proponents will be able to get projects started as soon as they have completed their online registration, provided they are following the rules in the regulation. This eliminates the step of waiting for the ministry to review and approve permits. It is not clear what the rules in the regulation will be and appears to eliminate review by ministry SAR staff. This does not signal a government that is interested in species protection. Review of the work of others always leads to better results for all.
Thirdly, the new proposal notes that the role of the Committee on the status of Species at Risk in Ontario (COSSARO) an independent science-based committee responsible for assessing and classifying species in Ontario will not change. What is concerning is that the government will have the discretion to remove protected species from the list. This is not public science and really removes the independence of this committee when species can be removed at the whim of the government.
Finally, the proposed amendments to the ESA would remove the requirements to develop recovery strategies, management plans, government response statements and the review of the progress of these from the legislation. This appears to be the loss of provincial science from species recovery planning, which is relied upon by other organizations to inform ways to recover species on their own lands. It also removes the onus on the government to recover species on the endangered species list, only protect what exists.
Premier Ford, you were elbow up all over the USA when they wanted to make us the 51st state. But these changes to the ESA are very American in the degredation of environmental legislation.
Submitted May 17, 2025 5:14 PM
Comment on
Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025
ERO number
025-0380
Comment ID
148067
Commenting on behalf of
Comment status