I am writing to express my…

I am writing to express my deep concern and opposition to the proposed changes to the Endangered Species Act, 2007 (ESA) and the introduction of the Species Conservation Act, 2025 (SCA). These changes would significantly weaken protections for Ontario’s most vulnerable species, prioritize short-term economic gains over long-term ecological health, and undermine science-based decision-making.

Key Concerns:
1. Dismantling Science-Based Protections
- The proposal grants the government discretion to ignore COSSARO’s classifications of at-risk species, politicizing what should be an independent, evidence-based process. Delisting or refusing to list species for economic reasons jeopardizes their survival.
- The removal of mandatory recovery strategies and management plans abandons Ontario’s commitment to species recovery, leaving no accountability for habitat restoration or population targets.

2. Narrowed Habitat Definitions
- The new definition of “habitat” excludes critical areas species rely on for feeding, migration, and other life processes. For example, reducing protections to only “dwelling places” (e.g., nests) ignores the broader ecosystems species need to survive. This will accelerate habitat fragmentation and decline.

3. Elimination of “Harassment” Protections
- Removing protections against harassment (e.g., disturbing nesting birds or stressed species) is unjustifiable and contradicts global conservation standards.

4. Fast-Tracking Harmful Activities
- Shifting to a “registration-first” approach allows projects to proceed without ministry oversight, relying on self-regulation by proponents. This risks irreversible harm to species, as seen in jurisdictions with similar deregulation.
- The claim that this will reduce delays for housing and infrastructure is misleading. The ESA already includes exemptions for these projects (e.g., *Ontario Regulation 242/08*), and delays are often due to underfunding—not the law itself.

5. Abandoning Stewardship Programs
- While the new Species Conservation Program promises increased funding, the wind-down of the Species at Risk Conservation Trust and other advisory bodies suggests a lack of commitment to collaborative, science-driven conservation.

6. Federal-Provincial Duplication
- The proposal frames federal protections (e.g., for migratory birds) as “duplication,” but these species need layered safeguards. Ontario should strengthen—not abandon—its role in protecting them.