To Whom It May Concern, I am…

To Whom It May Concern,

I am writing to express my strong opposition to the proposed interim amendments to the Endangered Species Act, 2007 (ESA) and the proposal to enact the Species Conservation Act, 2025 (SCA), as outlined in ERO Notice 025-0380. While the proposal claims to streamline processes, it fundamentally weakens protections for Ontario's most vulnerable species and prioritizes economic considerations over environmental stewardship.  

My primary concerns regarding this proposal include:

1. Erosion of Core Protections: The proposal significantly narrows the definition of "habitat" to limited areas like dens, nests, or critical root zones, ignoring the broader landscapes species often need for foraging, migration, and survival. Removing the prohibition against "harassing" species further diminishes protection against harmful disturbances. These changes create loopholes that could permit detrimental activities in areas vital to species persistence, under the guise of providing "clarity".  

2. Prioritization of Economy Over Environment: Explicitly amending the purpose of species legislation to include "social and economic considerations, including the need for sustainable economic growth" signals a dangerous shift. This could allow economic factors to override scientifically recognized conservation needs, fundamentally undermining the goal of protecting and recovering species at risk.  

3. Increased Political Interference in Listing: Granting the government discretion to not list species assessed as at risk by the independent Committee on the Status of Species at Risk in Ontario (COSSARO), and even discretion to remove currently protected species, injects political considerations into what should be a science-based process. This undermines COSSARO's role and risks leaving vulnerable species unprotected for non-scientific reasons.  

4. Abandonment of Recovery Planning: Removing the legislative requirements to develop recovery strategies, management plans, and government response statements eliminates crucial tools for proactive species recovery and removes government accountability. Relying solely on the Ministry's discretion to develop guidance "when and where it is needed" is insufficient and lacks transparency.  

5. Risks of the "Registration-First" Approach: Shifting nearly all authorizations to a registration-first system largely removes expert Ministry oversight before potentially harmful activities proceed. It relies heavily on proponent self-compliance with rules yet to be defined. While presented as efficient, this approach risks cumulative negative impacts escaping proper assessment and mitigation, functioning similarly to a "pay-to-slay" system where activities proceed with minimal upfront scrutiny.  

6. Reduced Accountability and Oversight: Winding down the Species Conservation Action Agency (SCAA) and removing the explicit mandate for advisory committees like the Species at Risk Program Advisory Committee reduces transparency and opportunities for independent expert advice and stakeholder engagement in species conservation efforts.  

7. Insufficient Consultation: A 30-day comment period is entirely inadequate for the public and experts to meaningfully review and respond to such sweeping changes, which include repealing one act and replacing it with another.  

While the proposal includes increased funding for a new Species Conservation Program and updated compliance tools, these measures do not compensate for the fundamental weakening of legislative protections, the increased potential for political interference, and the reduction in proactive planning and oversight. The claim that the current ESA causes "unnecessary delays and costs" should not be used to justify dismantling essential environmental protections.  

Therefore, I strongly urge the Ministry to withdraw this proposal (ERO 025-0380). Ontario needs stronger, not weaker, science-based legislation to protect biodiversity and ensure the recovery of species at risk for future generations. The focus should be on improving the implementation of the existing Endangered Species Act, not replacing it with a framework skewed towards facilitating development at the expense of nature.

Thank you for considering my input on this critical matter.