Under the proposed new…

Under the proposed new approach, instead of waiting for the ministry to approve permits, most proponents will be able to begin an activity immediately after registering. How can Species at Risk be protected if work is allowed to commence before the habitat studies have been completed?

The government should not have the discretion to remove protected species from the list unless COSSARO has independently assessed that the species is no longer at risk in Ontario.

The concept of "harass" should be kept in the legislation as it is one of the more common pathways of harm that could result in the extirpation or extinction of the species. It is already hard to enforce "harassment" as the legislation stands. The removal of this concept would make it impossible.

I strongly recommend against narrowing the definition of "habitat" for animals to only occupied or habitually occupied dwellings and the surrounding area. It is a basic concept that species require more than just a dwelling place for survival (e.g. foraging and migratory habitats are also important). Additionally, "the area immediately surrounding a dwelling place" is unclear. Quantitative buffers must be defined (e.g. in metres) that are specific to the needs of each species. Additionally, who will determine what qualifies as "immediately surrounding"? I strongly recommend an independent, science-based organization or group. For vascular plants, the "critical root zone" is unlikely to protect seeds or spores of the species. How would this not have an impact on the viability rate of the plant's progeny?

Many species (such as migratory birds and aquatic species) are not adequately protected under Federal legislation but have some additional provincial protections in Ontario. Eliminating these provincial protections would leave these species even more vulnerable to population decline than before.

The Endangered Species Act was once considered strong legislation for Species at Risk protection and may one day become so again. However, repealing this legislation and ultimately sacrificing our natural assets under the guise of fighting a trade war is bad business. Scrapping this legislation mirrors efforts by the US government, which the Ontario government claims to be protecting us from with the "Protect Ontario by Unleashing Our Economy Act, 2025". Ontarians will see through this.