I am writing to express my…

I am writing to express my strong opposition to the proposed amendments to Ontario’s Endangered Species Act, 2007 and the eventual repeal and replacement of the ESA with the Species Conservation Act, 2025. While the stated goals of streamlining project approvals and supporting economic development may appear beneficial, these changes fundamentally weaken legal protections for at-risk species in Ontario and represent a dangerous shift in environmental policy.

1. Weakening Science-Based Decision-Making
The proposed legislation undermines the authority of the Committee on the Status of Species at Risk in Ontario (COSSARO) by giving the government discretionary power to add or remove species from the Protected Species in Ontario List. This politicizes what must remain an objective, science-based process. Allowing elected officials to override independent expert assessments introduces the risk of decisions being made based on short-term economic interests rather than long-term ecological sustainability.

2. Registration-First Approach Reduces Oversight and Accountability
The shift to a “registration-first” system eliminates meaningful oversight. Under this model, proponents can begin potentially harmful activities immediately after registering, without prior ministry review or approval. This risks irreversible harm to species and habitats before adequate environmental protections can be verified or enforced. The current permitting system—though sometimes slow—is a necessary safeguard for ensuring that activities meet conservation standards.

3. Redefinition of “Habitat” Narrows Protections
The new definition of “habitat” drastically narrows what is considered critical for species survival, excluding important foraging, dispersal, and seasonal use areas. This ignores the ecological reality that many species require large, interconnected landscapes to thrive. Simplifying habitat definitions for administrative convenience should not come at the cost of effective species protection.

4. Elimination of Recovery Strategy Requirements Is Harmful
Removing the legislative requirement to produce recovery strategies, government response statements, and progress reports will significantly weaken Ontario’s capacity to monitor and respond to the needs of endangered species. These documents are not bureaucratic hurdles—they are essential tools for accountability, planning, and transparent conservation action.

5. Reduced Protections for Aquatic Species and Migratory Birds
By eliminating the need for provincial permits for federally protected aquatic species and migratory birds on non-federal land, Ontario is abdicating its responsibility to enforce complementary protections. This hands-off approach may leave significant gaps in protection during critical stages of project planning and implementation.

6. Risk of Misuse and Abuse
With fewer permits, fewer reporting requirements, and no clear advisory committee mechanism, the proposed system reduces checks and balances. Coupled with the winding down of the Species at Risk Conservation Trust and advisory bodies, it leaves less room for expert input, transparency, and public participation in decision-making.

7. Conservation Should Not Be a Barrier—But It Must Be a Priority
While it is important to reduce unnecessary red tape, this must not come at the cost of irreversible damage to Ontario’s biodiversity. A strong economy and a healthy environment are not mutually exclusive. True sustainable development requires robust, science-informed conservation laws that ensure economic progress does not come at the expense of the province’s most vulnerable species.

Conclusion
The proposed changes represent a serious erosion of environmental protections under the guise of efficiency. Ontario has a responsibility—ethically, ecologically, and legally—to safeguard its natural heritage for future generations. I urge the government to withdraw the proposed changes to the ESA and the SCA, and to recommit to science-based, transparent, and enforceable species protection policies.