As an environmental…

As an environmental scientist and engaged citizen of Ontario, I strongly oppose the proposed repeal of the Endangered Species Act, 2007 (ESA) and its replacement with the Species Conservation Act, 2025 (SCA). The proposed changes severely undermine science-based protections for at-risk species and represent a step backward in ecological stewardship.

While COSSARO remains a science-based body under the proposal, the discretionary power given to government to list or delist species on the Protected Species in Ontario List introduces a dangerous precedent: it enables political interference in what should be a strictly scientific process. The strength of Ontario’s current ESA lies in its requirement that all species assessed as at-risk by COSSARO be listed and afforded protection. By contrast, the proposed SCA could allow governments to disregard scientific evidence when politically inconvenient — a marked departure from global best practices in conservation.

In comparison:
-Canada’s federal Species at Risk Act (SARA) mandates ministerial action within timelines once COSEWIC assesses a species.
-U.S. Endangered Species Act requires listing decisions based "solely on the best scientific and commercial data available" and is legally binding.

Allowing proponents to begin activities immediately upon registration, with no prior review of impacts by experts, fundamentally weakens the precautionary approach that underpins effective conservation. It effectively shifts the burden of risk from developers to species.

This contradicts:
-The precautionary principle adopted in the Canadian Environmental Protection Act and international biodiversity agreements.
-Global conservation norms which require environmental assessments prior to project authorization (e.g., European Union's Habitats Directive).

The proposed narrowing of the habitat definition excludes broader ecological contexts critical for species recovery and survival. Species rely not only on core dwelling structures like nests or dens, but also on migration corridors, foraging areas, and other landscape-level features. This proposal reduces the ability to maintain ecological integrity, a concept at the heart of ecosystem-based management, and contravenes:
-The Convention on Biological Diversity, to which Canada is a signatory.
-Ontario’s own Biodiversity Strategy, which emphasizes landscape-scale conservation and connectivity.

The proposed habitat definition would be the equivalent to defining a person's home to their bedroom, ignoring all other critical aspects of a person's life.

Eliminating the legal requirement to produce recovery strategies, response statements, or review progress directly undermines transparency, accountability, and adaptive management. These strategies are crucial not just as planning tools but as public commitments to long-term conservation outcomes. In contrast:
-Under SARA, federal and provincial agencies must publish detailed recovery strategies with measurable objectives and timelines.
-The U.S. ESA similarly requires formal recovery planning and regular reviews of delisting criteria.

Removing the express ability to establish an advisory committee, and winding down the Species at Risk Program Advisory Committee, signals a reduction in participatory governance, especially when meaningful Indigenous consultation is already lacking in environmental decision-making processes.
Best practices across Canada and internationally increasingly emphasize the inclusion of Indigenous knowledge and co-governance models in species at risk conservation.

Although the government frames this bill as “balancing” economic and ecological considerations, the actual structure of the SCA:
-Emphasizes deregulation and speed for developers,
-Reduces enforceable obligations,
-Introduces uncertainty and fragmentation in species protection.

This proposal, ironically framed as a conservation measure, removes the very tools and standards required to deliver effective conservation outcomes.

Ontario’s Endangered Species Act, 2007 has been internationally recognized as a leading piece of conservation legislation. While administrative improvements can be made, dismantling its core safeguards in the name of expediency sets a perilous precedent for biodiversity in our province.

I urge the Ontario government to:

-Reject the repeal of the ESA,

-Preserve mandatory listing and habitat protection mechanisms,

-Improve permitting timelines through resourcing and coordination — not deregulation,

-Uphold the precautionary principle and strengthen, not weaken, recovery planning and ecological protections.

Protecting Ontario’s biodiversity is not a barrier to prosperity. It is the foundation of long-term environmental and economic resilience.