This feedback submission is…

This feedback submission is on behalf of Shake Up The Establishment (SUTE), a youth-led national registered non profit organization (#1190975-4) dedicated to addressing climate and social justice across what is currently Canada.

We have the following recommendations to the Ontario provincial government regarding the proposed changes to the Endangered Species Act, 2007, and the proposal for the Species Conservation Act, 2025, which are expanded upon in the attached supporting document:

1. These Acts must have mandated accountability and reporting measures to ensure that the government is effectively protecting and conserving at-risk species and habitats.
a) There must be clearly mandated regulations to the government on the protection of species and habitats at risk.
b) It is vital that there is still a body involved in implementing the Acts whose priority is “positive outcomes for certain designated species”.
c) Financial punishments must go back into supporting protection and conservation of at-risk species and habitats, whether through the Fund or a different regulatory body.
d) There should be a public database or documentation that the public can use to hold violators accountable.

2. Permitting, registering, approval, and listing processes must require in-depth research and analysis, and cannot allow for political and economic concerns to override harms to species and habitats at risk.
a) The government must ensure appropriate and in-depth consultations with Indigenous and local communities, scientists, and other stakeholders and experts before allowing for projects and activities to proceed.
b) There needs to be stronger accountability measures as a part of the registration process, including having a body responsible for ensuring that registered activities are “following the rules in regulation” when starting operations.
c) The definition of habitat must be kept more broad to ensure the protection and conservation of resources and ecosystems to allow for species to not only survive but thrive.
d) Resource protection must be integrated into what is considered a habitat within these Acts.

3. The government must invest in conservation efforts that are led by Indigenous and local communities, and ensure that they are consistently consulting with the public.
a) There should be a funding stream dedicated to Indigenous-led programming, including the development of Indigenous Protected and Conserved Areas.
b) It is vital that Indigenous communities be able to lead decision-making and activities across the province related to the protection and conservation of at-risk species and habitats.
c) The production of all rules and regulations for registered activities must be consulted upon by Indigenous and local communities and other experts and stakeholders to ensure that economic needs are not prioritized over the wellbeing of species and habitats.
d) The government must maintain spaces for community members to be in direct contact with the government to ensure that there is accountability on the effectiveness of protection and conservation efforts.
e) The government must ensure they are consulting Indigenous communities in accordance with the principles of free, prior, and informed consent as laid out in the United Nations Declaration on the Rights of Indigenous Peoples.
f)The government should be having Indigenous communities lead decision-making processes throughout implementation of the Acts
g) The government must be transparent about how they are obtaining input and advice and who from, so that residents can hold them accountable to the decisions being made.