I understand the Ministry is…

I understand the Ministry is looking for input on specific aspects of previous policies and technical direction to be retained; which components of the guidance is of greatest interest; which species
groups would most benefit from habitat guidance; and, any other advice or feedback.

Given the limitations to the definition of habitat under the Species Conservation Act, it is unclear how such guidance can actually be applied in a way that benefits species conservation.
This proposal to enable the Species Conservation Act will only further undermine progress on the Ontario Biodiversity Strategy and further imperil our most vulnerable species.

To determine the possible impact of an activity, it is necessary to determine risk to survival of the species and habitat in question, as was included in guidance under the Endangered Species Act. It is not possible to determine risk to survival of a species with any degree of certainty if all habitat (i.e. shelter, food, migration, reproduction, etc.) required for a species’ survival is not being considered in the assessment, as proposed under the Species Conservation Act.

The robust, science-based approach to defining habitat that existed under the Endangered Species Act, before the passage of Bill 5, must be reinstated before any guidance can be developed for assessing the impact of activities to a protected species or species’ habitat.

The Ministry must restore the Endangered Species Act and commit to strengthening protections for our most vulnerable species. The far weaker Species Conservation Act is not the answer

The Species Conservation Act is inadequate for managing species at risk in the midst of a
biodiversity crisis, specifically due to:

- the limited definition of ‘habitat’ compared to the Endangered Species Act
- the discretionary listing of species, removing an independent and science-based assessment approach
- the offloading of responsibility for migratory birds and aquatic species to the federal government
- the registration first approach
- the elimination of recovery strategies

I do not accept that economic uncertainty requires sacrificing our most vulnerable species.