As an environmental non…

As an environmental non-profit organization deeply committed to the protection of Ontario’s biodiversity and the long-term health of its ecosystems, we are writing to express our strong opposition to the proposed changes to the Endangered Species Act (ESA) and the creation of the new Species Conservation Act (SCA), 2025. These changes, under the Protect Ontario by Unleashing Our Economy Act, 2025, represent a significant rollback in species and habitat protection, driven by economic interests rather than ecological science or sound conservation policy.

1. Registration-First Model Undermines Oversight and Protection
Transitioning nearly all species-related authorizations to a registration-first approach effectively removes proactive oversight from the Ministry of the Environment, Conservation and Parks. While this may reduce administrative burdens, it introduces a high risk of non-compliance, especially in high-impact industries like infrastructure, mining, and housing development. Under this model, harmful activities can commence immediately upon registration, with no pre-activity vetting by ecological experts or the Ministry. This places the burden of enforcement entirely on post-hoc compliance, which is notoriously difficult, underfunded, and reactive in nature.

2. Discretion Over Species Listing Politicizes Conservation
While the government claims that COSSARO will retain its scientific classification role, giving elected officials the discretion to add or remove species from the Protected Species List creates the risk of politicizing species protection. Scientific assessments must remain the sole basis for listing and de-listing species. Allowing government discretion over listings opens the door for economic or development pressures to override science-based decisions, potentially leaving threatened species unprotected.

3. Removal of Mandatory Recovery Planning Is Short-Sighted
Eliminating legislative requirements for recovery strategies, government response statements, and progress reviews severely undermines the conservation of at-risk species. These tools are essential to ensure that species not only avoid extinction but can recover viable populations and ecological roles. Voluntary guidance lacks the force, consistency, and accountability needed for real recovery. Dismantling these requirements suggests that species recovery is not a priority.

4. Redefinition of Habitat Narrows Protections
The proposed new definition of “habitat” significantly narrows the scope of what is protected under law. By focusing only on core physical dwelling places (like nests or dens), the revised definition fails to consider the broader ecological context that species depend on—such as feeding areas, migration corridors, and seasonal ranges. This contradicts ecological science, which emphasizes that habitat is not static or strictly physical, but complex, dynamic, and interconnected.

5. Environmental Protections Are Being Sacrificed for Economic Expediency
This legislative shift appears to be motivated not by environmental concern, but by a desire to speed up project approvals and reduce “delays” for industry. While economic development is important, it cannot come at the cost of biodiversity, ecosystem services, and the resilience of Ontario’s natural heritage. Healthy ecosystems provide vital services—clean water, air purification, carbon storage, climate regulation, flood mitigation, and pollination—that underpin both human health and economic sustainability. Gutting species protections for short-term economic gain is both irresponsible and counterproductive.

6. Duplication with Federal Law Is Misrepresented
While eliminating duplication between provincial and federal species laws may sound efficient, it risks leaving aquatic species and migratory birds inadequately protected. The federal government’s enforcement capacity is limited, particularly on non-federal lands, and complementary provincial protections are essential to fill enforcement gaps and ensure timely, local response to environmental threats.

7. The Wind-Down of the Species at Risk Conservation Fund and SCAA Reduces Accountability
Ending the Species Conservation Action Agency (SCAA) and the funding model that required developers to contribute financially when impacting species removes a key mechanism for accountability and offsetting harm. The proposed approach has not clarified how new funding will be equitably and transparently distributed, nor whether it will be tied to measurable recovery outcomes. Simply shifting funds to government-controlled discretionary spending without accountability or stakeholder oversight is a regression in stewardship.

Conclusion
The proposed amendments to the ESA and the enactment of the SCA represent a systematic weakening of species at risk protection in Ontario. They prioritize deregulation, political discretion, and industry convenience over ecological integrity, science-based decision-making, and long-term sustainability. These changes will make it harder—not easier—for at-risk species to survive, let alone recover.

We urge the Ontario government to halt the implementation of these proposals and instead engage meaningfully with Indigenous communities, scientists, conservation organizations, and the public to strengthen, not erode, protections for Ontario’s most vulnerable species. A healthy environment is not an obstacle to economic prosperity—it is its foundation.