Hello, I strongly oppose the…

Hello, I strongly oppose the entirety of "Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025". I am an Ontarian and Ecologist with experience and expertise in Ontario's Species at Risk and monitoring their long term populations and habitat usage. Due to my professional and academic experiences, I urge you to take my comments into consideration.

The Endangered Species Act (ESA) was created to protect species at risk of becoming extinct in Ontario. The proposed changes are a serious threat to Ontario's Species at Risk, if these changes occur, we will risk losing species of wildlife from Ontario. Ontario wildlife is a pillar of the natural experience of Ontario for residents and tourists.

I strongly oppose the removal of the term “harass” from species protections, which essentially means “disturbance". Mitigating disturbances to species at risk during project development is one of the most effective ways of preventing wildlife injury, site abandonment, or mortality. Disturbance (or harassment) to an individual often leads to the abandonment of a dwelling, nest, roost, etc, and can lead to harm or mortality of the individual and/or their young.

I strongly oppose the proposed changes to the definition of "habitat". Currently in the ESA, “habitat” includes 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 proposed changes to the definition of "habitat" includes only the area immediately surrounding those dwellings listed above. This is essentially useless: an animal needs additional habitat within their home range to complete their life cycle, not just a small buffer around a site.

I strongly oppose the proposed registration system. Currently in the ESA, proponents need to acquire a permit if their project activities are in violation of the Endangered Species Act, which requires review by the Ministry. Changes from this proposal would only require proponents to register harmful activities, and can proceed with those activities immediately after registration. If proponents do not need to wait for a permit, this suggests there will be no oversight on activities that can harm or kill species at risk, which could be detrimental to Species at Risk.

I strongly oppose the removal of the requirements to develop recovery strategies and management plans, government response statements, and reviews of progress from legislation. Each species is unique in biology, habitat requirements, and life processes. It is imperative that each species are evaluated and assessed individually, and recovery strategies are critical documents for ecologists and impact assessment practitioners to assess and mitigate potential project impacts to Species at Risk.
I strongly oppose allowing the government to have discretion to remove protected species from the list of protected species. This should be left to scientists and experts, and not to governments who will always prioritize development over species protections.

To summarize, I strongly oppose all proposed changes to the Endangered Species Act. It is obvious that this Proposal is not to the benefit of Species at Risk but is to benefit developers. Acts like the ESA were created to protect species from becoming endangered, and it is the right of Ontarians to enjoy our provinces wildlife species for generations to come.

Please consider this for the future the nature of Ontario and the home in which we all live and rely on.