The new proposal contains…

The new proposal contains significant weaknesses, risks of politicization of environmental protection, and replaces enforcement with voluntarism in a new of key areas. What the current government has suggested is insufficient and should not be adopted:
1. Undermining of Scientific Integrity and Oversight
Government Discretion Over Listing: While the proposal retains COSSARO as a science-based advisory body, the government is granted discretionary power to add or remove species from the protection list. This undermines scientific independence and opens the door to politically or economically motivated decisions, weakening the evidentiary basis for protection.
Risk: Politicization of species protection can lead to delayed or denied listings, especially where development interests conflict with conservation.
2. Weakening of Habitat Protections
Narrowed Habitat Definition: The redefinition of habitat drastically reduces spatial and ecological scope, focusing only on immediate surroundings of nests or root zones. This neglects broader ecosystem interdependencies (migration routes, foraging ranges, hydrological systems), which are crucial for species survival.
Exclusion of ‘Harassment’: Removing the prohibition on “harassment” limits protections against disruptive human behavior (e.g., repeated disturbances that alter feeding or mating behavior), which science shows can be as damaging as direct harm.
3. Legal and Procedural Deregulation
Registration-First Model: Moving from a permit-based system to a self-registration system minimizes government oversight. Proponents can proceed with projects immediately upon registration, raising risks of non-compliance, misreporting, or damage before review.
Loss of Public Accountability: This approach erodes transparency, reduces the window for community or Indigenous input, and shifts decision-making power away from regulators toward developers.
4. Dismantling of Recovery Planning
Elimination of Recovery Strategies and Progress Reviews: Removing legislative requirements for recovery documents means no binding recovery trajectory or accountability for improvement. This undermines adaptive management, a cornerstone of effective conservation biology.
5. Reduction in Interjurisdictional Protection
Exclusion of Federally Listed Species: By removing provincial protections for federally protected aquatic and avian species under SARA, the proposal creates regulatory gaps. The federal government may lack capacity or political will to enforce protections on non-federal lands, leading to fragmented protection regimes.
6. Erosion of Public and Expert Participation
Elimination of Advisory Committees: The winding down of the Species at Risk Program Advisory Committee and lack of guaranteed replacements removes a key forum for stakeholder, scientific, and Indigenous input into policy and implementation.
7. Misuse of “Balance” Language to Justify Deregulation
Framing the changes as a “reasonable, balanced approach” and emphasizing “sustainable economic growth” masks the deprioritization of species protection in favor of development. The language of balance often functions rhetorically to justify deregulatory and pro-growth biases.
8. Risk of Greenwashing Voluntary Programs
Voluntary Conservation Programs are emphasized as replacements for regulatory action, but they often lack accountability, enforceability, and adequate scope. They may serve as greenwashing tools while allowing harmful activities to proceed under the guise of offset or stewardship.
9. Loss of the Polluter Pays Principle
Dismantling of the Species Conservation Action Agency and Fund removes mechanisms that required developers to compensate for damage. This weakens the internalization of environmental costs, a key tenet of responsible environmental governance.
10. Delayed or Insufficient Regulation Development
The framework depends on future regulations yet to be written, creating a vacuum in which activities can proceed with uncertain or incomplete safeguards, potentially resulting in irreversible harms during the regulatory transition.
Clear conclusion to be drawn here:
The proposed SCA framework represents a rollback of environmental protections under the guise of efficiency and economic growth. It prioritizes deregulation over ecological responsibility, centralizes discretionary power, and diminishes public oversight and scientific authority. Despite stated intentions to protect species, the structural changes subordinate biodiversity to development, with consequences that may be irreparable for vulnerable species and habitats in Ontario. It should be removed from the table and replaced with something not containing the weaknesses and prejudices outlined above, or the existing legislation should be left alone.