Comment
• I oppose the plan to amend and ultimately repeal the Endangered Species Act (Schedule 2).
• for the following reasons I oppose the proposed new Species Conservation Act, 2025 (Schedule 10), which would empower Cabinet to override science-based evidence in species protection decisions:
o I oppose replacing the current requirement for species-specific authorizations with a voluntary online registry—eliminating expert review and the obligation to consider safer alternatives or mitigation.
o I oppose redefining habitat for species at risk that does not include all elements of their life cycle requirements. Habitat is not a pin on a map. It is not limited to a nest, den, or the area “immediately surrounding” an animal. It is an entire interconnected system. The proposed definitions ignore this scientific reality—and in doing so, put Ontario’s biodiversity at irreversible risk.
o I oppose the elimination of recovery plans and compensation requirements to contribute to habitat improvements or re-creation elsewhere when impacts are unavoidable.
• I oppose the creation of “special economic zones” (Schedule 9), which would exempt “trusted proponents” and “designated projects” from complying with key provincial laws, municipal by-laws, and First Nations consultation requirements. The act contains no limits, no criteria, no process or procedures to limit its application. Further, this bill transfers the power to the Cabinet with no legislative and certainly no public oversight. Schedule 9 must be removed until such time as reasonable guardrails are established that work within the rule of law, civil rights and our democratic system.
Submitted May 17, 2025 7:18 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
148341
Commenting on behalf of
Comment status