I appreciate the government…

I appreciate the government’s effort to modernize Ontario’s species at risk framework and recognize the potential benefits of streamlining approvals for infrastructure and development. However, I am deeply concerned that the proposed repeal of the Endangered Species Act, 2007 (ESA) and its replacement with the Species Conservation Act, 2025 (SCA) will significantly weaken protections for vulnerable species and their habitats.

My key concerns are as follows:

Discretionary Protections: Giving the government discretion to decide which COSSARO-assessed species receive protection removes objectivity from what should remain a science-based process.

Registration-First Approach: Shifting most approvals to a registration system removes critical review of site-specific risks. While I support efficiency, this approach lacks safeguards to ensure real impacts are mitigated.

Reduced Habitat Protections: The new, narrower definition of habitat fails to account for essential ecological functions like foraging or movement, leaving critical areas unprotected.

Elimination of Recovery Planning: I’m concerned that removing the requirement to develop recovery strategies and progress reviews reduces accountability and coordination of species recovery efforts.

Loss of the Conservation Fund and Advisory Committee: Phasing out the Species at Risk Conservation Fund and formal advisory structures will reduce transparency and limit opportunities for collaborative, landscape-scale conservation.

Regulatory Gaps with Federal Protections: Removing provincial requirements for species also protected under federal law could create gaps in oversight—especially if federal approvals are delayed or under-resourced.

I respectfully recommend the following:

Maintain automatic protection for all species classified by COSSARO as extirpated, endangered, or threatened.

Keep permit-based oversight for activities with moderate or high risk to species or habitats.

Expand the definition of habitat to reflect species’ full ecological needs.

Retain a legislated recovery planning process to guide long-term conservation.

Ensure dedicated, transparent funding and retain mechanisms for expert and stakeholder input.

Streamlining the system should not mean weakening species protection. I urge the government to ensure that any new legislation remains grounded in science, transparency, and a strong commitment to Ontario’s biodiversity.