ERO Submission – Public…

ERO Submission – Public Comment Opposing Proposed Species Conservation Act, 2025 (ERO #025-0380)

Subject: Opposition to ERO Proposal 025-0380 – Proposed Replacement of the Endangered Species Act, 2007 with the Species Conservation Act, 2025

I am writing to express my strong opposition to the proposed legislative changes under ERO #025-0380, which would repeal Ontario’s Endangered Species Act, 2007 (ESA) and replace it with the Species Conservation Act, 2025 (SCA).

This proposal significantly weakens protections for Ontario’s most vulnerable species and ecosystems under the guise of streamlining conservation processes. Below are my key concerns:
1. Erosion of Science-Based Decision-Making

The proposed SCA removes the obligation for the government to list at-risk species based on recommendations from the Committee on the Status of Species at Risk in Ontario (COSSARO). This shift from science-based listing to politically influenced decision-making undermines the credibility and effectiveness of Ontario’s species-at-risk program.
2. Automatic Activity Registration Endangers Species

Allowing proponents to proceed with potentially harmful activities through automatic registration, before proper review or mitigation planning, exposes species and habitats to irreversible damage. This approach prioritizes development over environmental due diligence and precaution.
3. Weakened Definition of Habitat

The proposed redefinition of “habitat” restricts protections to narrowly defined areas and periods, potentially excluding vital migratory routes, breeding grounds, and seasonal habitats. This fragmented approach is ecologically flawed and inconsistent with modern conservation science.
4. Elimination of Recovery Planning Requirements

The removal of mandatory recovery strategies, action plans, and regular reporting eliminates accountability and undermines long-term species protection. Voluntary approaches have repeatedly failed to stop biodiversity loss and should not replace structured recovery planning.
5. Reduced Public and Indigenous Participation

The elimination of public and Indigenous advisory bodies curtails transparency and meaningful engagement. This move contradicts the province’s commitments to reconciliation and inclusive environmental governance.
6. Regulatory Gaps Due to Federal Exemptions

By exempting species already protected under federal legislation, the SCA risks creating enforcement gaps — especially on provincial lands where federal oversight may be limited. Coordinated, complementary protections are essential, not offloaded responsibilities.
7. Dismantling of the Species Conservation Fund Oversight

The proposed dissolution of the Species Conservation Action Agency, and reallocation of its funds into general government revenue, removes critical oversight and transparency. Without clear accountability, conservation funding risks being diverted or mismanaged.
Conclusion

Ontario’s Endangered Species Act, 2007 is one of the most comprehensive and respected conservation laws in Canada. While updates and refinements are always possible, this proposal dismantles core legal protections and replaces them with a deregulated, developer-centric framework.

I respectfully urge the Government of Ontario to:

Maintain science-based species listing;

Require permits and comprehensive review for potentially harmful activities;

Retain a broad, ecologically grounded definition of “habitat”;

Reinstate mandatory recovery planning requirements;

Protect public and Indigenous involvement in species protection;

Ensure transparency and proper stewardship of conservation funds.

Now is the time to strengthen, not dismantle, Ontario’s commitment to biodiversity.

This proposal should be withdrawn.