The proposed interim changes…

The proposed interim changes to Ontario’s Endangered Species Act, 2007, and the introduction of the Species Conservation Act, 2025, as outlined in ERO #025-0380, warrant careful reconsideration. While the intent to streamline processes and integrate socio-economic considerations is understandable, several aspects of the proposal could inadvertently compromise the province's commitment to biodiversity conservation.

**1. Potential Undermining of Science-Based Protections**

The proposal maintains the role of the Committee on the Status of Species at Risk in Ontario (COSSARO) as an independent, science-based body responsible for assessing species. However, granting the government discretion to add or remove species from the protected list, even when COSSARO has identified them as at risk, could lead to decisions that are influenced by factors other than scientific evidence. This shift may weaken the objectivity and credibility of species protection efforts.([Environmental Registry of Ontario][1], [Ontario OUT of DOORS][2])

**2. Concerns Over the Registration-First Approach**

Transitioning from a permit-based system to a registration-first model allows proponents to commence activities immediately after registration, provided they adhere to set regulations. While this aims to reduce delays, it may inadvertently increase the risk of harm to species and habitats if oversight and enforcement mechanisms are not sufficiently robust. Ensuring that activities do not negatively impact species requires thorough pre-activity assessments, which may be compromised under this new approach.([Environmental Registry of Ontario][1])

**3. Redefinition of Habitat and Removal of 'Harass' Prohibition**

The proposed redefinition of "habitat" focuses narrowly on specific dwelling places and their immediate surroundings. This limited scope may exclude critical areas essential for feeding, migration, and other life processes. Additionally, removing the prohibition against "harassing" species could diminish protections against disturbances that, while not physically harmful, can still adversely affect species' well-being and survival.([Environmental Registry of Ontario][1])

**4. Elimination of Mandatory Recovery Strategies**

The proposal suggests removing the legislative requirement for the government to develop recovery strategies and management plans for species at risk. These strategies are vital for outlining clear, science-based actions to aid in species recovery. Their elimination could lead to inconsistent or inadequate conservation efforts, hindering the effective recovery of vulnerable species.([Ontario OUT of DOORS][2])

**5. Disbanding of the Species at Risk Conservation Fund**

The plan to wind down the Species at Risk Conservation Fund and transfer its resources to the government, without a clear framework for their allocation, raises concerns about the continuity and effectiveness of funding for species protection initiatives. Ensuring that these funds are used transparently and effectively is crucial for maintaining public trust and achieving conservation goals.([Environmental Registry of Ontario][1])

**6. Introduction of Special Economic Zones**

The broader legislative context includes the potential establishment of Special Economic Zones, where certain provincial and municipal laws could be suspended. Such zones may pose risks to environmental safeguards, including those protecting endangered species, if not carefully regulated and monitored.([Canadian Environmental Law Association][3])

In conclusion, while the objectives of economic growth and streamlined processes are important, they should not come at the expense of Ontario's rich biodiversity. A balanced approach that upholds rigorous scientific standards, ensures robust protections, and fosters transparent, accountable governance is essential for the sustainable coexistence of development and conservation.

[1]: https://ero.ontario.ca/notice/025-0380?utm_source=chatgpt.com "Proposed interim changes to the Endangered Species Act, 2007 ..."
[2]: https://oodmag.com/province-replacing-endangered-species-act/?utm_sourc… "Province replacing Endangered Species Act - Ontario OUT of DOORS"
[3]: https://cela.ca/action-alert-bill-5/?utm_source=chatgpt.com "Action Alert - Bill 5 Would Harm Environmental Safeguards and ..."