I am writing to express my…

I am writing to express my feedback regarding the proposed amendments to Ontario's Endangered Species Act (ESA) and the introduction of the Species Conservation Act (SCA). While I support efforts to streamline processes, reduce duplication between federal and provincial species protections, and provide clarity for project proponents, I have serious concerns regarding the potential weakening of environmental protections under the proposed changes.

Positive Aspects of the Proposed Changes:

1. Elimination of Duplicative Processes:

The removal of redundant requirements for species protected under the Federal Species at Risk Act (SARA) is a sensible change, as it avoids unnecessary duplication and improves administrative efficiency.

2. Improved Clarity for Proponents:

The move to establish clearer definitions of "habitat" and other terms can help reduce confusion and ensure that species protections are implemented in a more predictable manner.

Primary Environmental Concerns:

1. Weakening of Species Protections:

The shift to a registration-first approach for nearly all species-related authorizations significantly reduces proactive oversight, creating a higher risk of harm to endangered species and their habitats.

Allowing the government to choose which species are added or removed from the protected list undermines the scientific authority of the Committee on the Status of Species at Risk in Ontario (COSSARO).

2. Narrowed Habitat Definition:

The revised definition of "habitat" only includes core areas directly used by species (e.g., nests, dens) and excludes critical surrounding ecosystems, which are essential for species survival.

3. Reduced Recovery Planning:

The elimination of mandatory recovery strategies, management plans, and progress reviews removes a key framework for ensuring the long-term survival of species at risk.

4. Voluntary Conservation Emphasis:

Replacing mandatory conservation actions with voluntary initiatives creates uncertainty and weakens the government's accountability for species protection.

5. Enforcement and Compliance Concerns:

The registration-first model reduces pre-activity scrutiny, making compliance more reliant on post-incident enforcement. This approach may allow harm to occur before corrective action is taken.

Recommendation:

I strongly urge the Ministry to reconsider aspects of the proposed amendments that may weaken species protections and instead focus on streamlining processes without compromising environmental safeguards. This can be achieved by:

1. Retaining the requirement for recovery strategies and management plans for at-risk species.

2. Ensuring that the government cannot override scientific recommendations from COSSARO.

3. Maintaining a broader habitat definition that protects essential ecosystems beyond direct nesting or denning sites.

4. Strengthening the compliance model with proactive inspections rather than relying solely on post-incident enforcement.

Thank you for considering my feedback.