I am concerned with the…

I am concerned with the proposal to repeal the Endangered Species Act and replace it with the Species Conservation Act.

My primary concerns revolve around the potential for weakened protection for species at risk due to several key changes:

1. Narrower Habitat Definition: This could exclude essential areas beyond immediate dwellings, hindering survival.
2. Non-Mandatory Recovery Strategies: The lack of legally required recovery plans could impede effective conservation efforts.
3. Politicization of Species Listing: Government discretion in listing, even after scientific assessment, raises fears of politically motivated exclusions.
4. Risks of "Registration-First" Approach: Reduced oversight and potential for harm without prior review are significant worries.
5. Weakened Enforcement: Limited enforcement powers could hinder immediate protection against illegal activities.
6. Reduced Transparency and Accountability: The removal of advisory committees and changes to processes could limit independent input and oversight.
7. Disregard for Indigenous Rights: Concerns exist about inadequate consultation and accommodation of Indigenous rights and knowledge.
8. Prioritization of Economic Growth: The explicit inclusion of economic considerations in the Act's purpose is seen as potentially overshadowing conservation goals.
9. Overall Risk of Biodiversity Loss: Critics fear these changes could accelerate the decline and extinction of species in Ontario.

The following are a few solutions to reverse or significantly amend the proposed changes to ensure stronger and more effective species at risk protection:

1. Maintain and Strengthen the Current ESA: Rather than a complete overhaul, focus on improving the existing ESA with stronger regulations and enforcement.
2. Retain a Broad and Ecologically Meaningful Habitat Definition: Ensure habitat protection encompasses all areas essential for a species' survival and recovery, based on scientific understanding.
3. Reinstate Mandatory Recovery Strategies: Legally require the development and implementation of science-based recovery plans with clear timelines and targets.
4. Uphold Science-Based Species Listing: Maintain an independent, scientific process for listing species at risk, minimizing political influence.
5. Ensure Robust Oversight for "Registration-First" Approach: If implemented, develop stringent regulations with clear standards, monitoring, and enforcement mechanisms to prevent harm.
6. Strengthen Enforcement Powers: Equip enforcement officers with the necessary tools and authority to effectively protect species and their habitats.
7. Enhance Transparency and Accountability: Maintain or strengthen independent advisory bodies and ensure accessible and transparent permitting and appeal processes.
8. Explicitly Recognize and Uphold Indigenous Rights: Integrate the duty to consult and accommodate Indigenous Peoples and respect Indigenous knowledge in all aspects of species at risk management.
9. Prioritize Biodiversity Conservation: Ensure that the primary purpose of the legislation is the protection and recovery of species at risk, with economic considerations being secondary and integrated in a sustainable manner.
10. Increase Funding and Resources: Allocate sufficient financial and human resources for effective species at risk research, monitoring, recovery actions, and enforcement.
11. Conduct Thorough and Meaningful Public and Indigenous Consultation: Ensure that all stakeholders have ample opportunity to provide input on any proposed changes to species at risk legislation.

In essence, the advocated solutions call for a return to a stronger, science-based, and legally binding framework for species at risk protection in Ontario, one that prioritizes ecological integrity and respects Indigenous rights while considering sustainability.

Finally, it was stated that "species at risk continue to be afforded protection under the Endangered Species Act, 2007" when the Ontario Wetland Evaluation System (OWES) was gutted under Bill23(2022). At the time the proposed There were 14,848 comments posted to the ERO and not one change to the proposed OWES was made.