As a scientist and…

As a scientist and conservation professional working in the realm of ecology and plant conservation for the last 7 years, and having worked on recovery teams for several Species at Risk vascular plants, I am deeply opposed to both the proposed interim changes to and eventual repeal of the Endangered Species Act, 2007 (ESA). The implications of these changes are enormous and will be catastrophic for Species at Risk.

As Canada’s most biodiverse province in species richness and ecosystem diversity, Ontario’s grasslands, temperate and boreal forests, wetlands and so much more are home to over 200 Species at Risk, with approximately 80% of these being vascular plants. We’ve already lost most of our forested area in southern Ontario, and the fact that habitat loss and fragmentation is the number one threat to all at-risk species speaks to the issues we already face in Ontario. It also highlights the importance of protecting what little intact ecosystems we still have to support Species at Risk.

Endangered species are not red tape. It is appalling to read that the purpose of the ESA (changed immediately upon acceptance of the interim period changes) will no longer be to solely protect and recover Species at Risk populations, but is instead in part to “tak[e] into account social and economic considerations, including the need for sustainable economic growth in Ontario”. Without the primary goal of protecting species, these changes fly in the face of national and international agreements signed by Canada and its provinces, through the Convention on Biological Diversity, 1992, the Accord for the Protection of Species at Risk,1996, the Pan-Canadian Approach to Transforming Species at Risk Conservation in Canada, 2018, Ontario’s Biodiversity Strategy (2023-2030), Canada’s 2030 Nature Strategy, among others. This gutting and eventual repeal of the ESA, which was initially signed in 1971 and overhauled for increased protection in 2007, takes us back decades—if not by a century. Ontario’s ESA was once considered one of the most robust protections for Species at Risk in Canada, and globally.

Provincial legislation is not a duplication of federal legislation. It was enacted because the policy framework prior to its implementation (both provincially and federally) was not strong enough to protect these vulnerable species, and currently has a much more extensive list (Species at Risk in Ontario List) than what is listed federally.

The following text discusses how these changes contradict EVERY current purpose of the ESA (numbered below).

1. To identify species at risk based on the best available scientific information, including information obtained from community knowledge and aboriginal traditional knowledge.

By giving the province the authority to remove (or add…) species to the Species at Risk in Ontario List, authority is removed from the Committee on the Status of Species at Risk in Ontario (COSSARO) which assesses and classifies species based on scientific information, community knowledge and Aboriginal Traditional Knowledge. In what seems to be an international trend of removing science from government decision-making, this is short-sighted and undemocratic.

2. To protect species that are at risk and their habitats, and to promote the recovery of species that are at risk.

Changing the definition of Species at Risk habitat to a, put simply, non-scientific definition and allowing for harassment of species will most certainly cause further decline in these populations that have already been assessed by COSSARO to be experiencing declines and, in the case of endangered species, are facing imminent extinction or extirpation. The use of the “critical root zone” as the definition of habitat has, unfortunately, already been used for some Species at Risk in Ontario but should not become the formal definition for all vascular plants given that this does not represent anything close to a functioning ecosystem—Species at Risk often depend on sensitive ecosystems that provide unique habitats.

The removal of species recovery documents (recovery strategies and management plans, government response statements, and reviews of progress) from legislation does not promote the recovery of species. If there is no strategy, planning or tracking the progress on recovery then how are the proposed changes protecting Species at Risk at all? Recovery has also been removed from the proposed new purpose of the ESA.

3. To promote stewardship activities to assist in the protection and recovery of species that are at risk.

By removing the requirement for recovery documentation and diluting Species at Risk funding into an nondescript Species Conservation Program supporting “voluntary activities”, these changes have the potential to dismantle decades of progress by species recovery teams and recovery programs developed by government and non-government organizations in as little as one year without funding.

To protect Species at Risk we need strategic conservation, not a project-by-project approach, and most certainly not “voluntary activities”. In my years consulting, I could not name one proponent that would engage in these activities voluntarily. Proponents should be held accountable for their actions, especially when it entails the destruction of Species at Risk and/or their habitats. One bucket of money for habitat restoration also has no guarantee that it will end up in the right hands, especially given that the Species Conservation Action Agency and Species at Risk Program Advisory Committee will be dissolved and there are no details on how funding will be allocated.

There is very little information within this ERO posting on what the new Species Conservation Act, 2025 will entail and how it will be implemented. No information has been provided on how it will “drive species protection and conservation”. However, a move towards a registration only approach will likely mean that Species at Risk and/or their habitats will be removed before recovery experts even have the chance to see them or know that they are there.

On a more personal level, we are living in the sixth mass extinction and it brings me deep ecological grief that the launch of my career has been nothing but fighting the incessant government changes that seem to seek the destruction of our environment. I do not wish for this to be the final blow to the ESA, and I look forward to the day that we can work together and work strategically with our government to protect our Species at Risk.

Thankyou for your time and consideration.