RE: ERO Number 025-0380 -…

RE: ERO Number 025-0380 - Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025

Thank you for the opportunity to provide comment on the proposed Species Conservation Act, 2025. These comments are in response to direction from the Council of the Town of Amherstburg, namely,

Council Resolution 20250512-008

THAT:
1. Administration BE DIRECTED to send a response to the comment period on Bill 5 in advance of the deadline provided by the Province of Ontario, May 17, 2025, identifying potential impacts and considerations in the Town of Amherstburg and any risks that may be born with these changes.

The Town of Amherstburg has a geographic area of approximately 184 square kilometres and over 16% of this area or 30 square kilometres is comprised of natural heritage features including many that are classified by COSSARO and are currently subject to the protective measures under the Endangered Species Act, 2007. The Town of Amherstburg has the largest quantity of natural heritage features in the County of Essex as measured by both total land area and percentage of total land area.

The Town of Amherstburg is concerned that the proposed repeal of the Endangered Species Act, 2007 through the proposed Species Conservation Act, 2025 will adversely impact extirpated species, endangered species, threatened species or special concern species that live in Ontario. Of particular concern are the proposed changes to definition of “habitat” that will have the effect of substantially decreasing the areas subject to protection by Provincial authority to that of where the animal’s dwelling-place is and the area immediately around the dwelling-place. The Town of Amherstburg urges the Province of Ontario to consider an ecosystems approach to environmental legislation that emphasizes the broader interactions of species over a larger geographic area.

The Town of Amherstburg appreciates this opportunity to provide comment to the Province of Ontario on this important matter.

Yours truly,

<original by email signed>

Valerie Critchley
Chief Administrative Officer
Town of Amherstburg

CA