RE: ERO 025-0380 “Proposed…

RE: ERO 025-0380 “Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025”
Dear Ministry,
The Central Ontario District of the Christian Farmers Federation of Ontario (CFFO) represents farming businesses within Simcoe County and York Region. The Christian Farmers Federation of Ontario (CFFO) is an Accredited Farm Organization representing the interests of over 4,000 farm families in Ontario who are called to the vocation of farming. CFFO policy promotes economically, socially, and environmentally sustainable farming, advocating that farmers receive fair return for their production and stewardship efforts.
The Central Ontario District of the Christian Farmers Federation of Ontario has significant concerns about the proposal to replace the current Endangered Species Act with the Species Conservation Act.
Simcoe County and York Region are home to environmentally sensitive areas, including the Minesing Wetlands, the Niagara Escarpment, Georgian Bay, Lake Simcoe and the Holland Marsh. Many rare and endangered species make their home in these and other suitable areas across the region. This region is also a quickly growing urban area, resulting in significant development pressure on these species and their habitat.
As significant landowners, farmers take their stewardship responsibilities very seriously regarding their farming practices and their responsibility to broader creation care. Many farmers voluntarily provide areas of their property intended to provide habitat to wild species, or make adjustments to their farming practices expressly to protect species at risk.
While we hope that all businesses in Ontario take the same care and consideration for their broader stewardship responsibilities, our laws set the minimum protection of species at risk across the province.
We recognize the government’s goals to simplify regulations, remove duplication and relieve administrative burden. We support efforts to:
• Avoid duplication with federal species at risk regulations and requirements
• Clarify rules and requirements to ensure they are easy to follow
• Increase government support for voluntary efforts to protect species at risk
However, the proposed Species Conservation Act, 2025 would no longer have species protection as its primary stated objective and would remove many aspects that ensure fair treatment and effective protection of all identified species at risk.
We recommend that:
• Legislation for species protection needs to have as a key objective protecting all species that are identified as at risk and promoting their recovery
• Species status and inclusion on the list of protected species should continue to be scientifically determined
• Definition of habitat for all species should include the area necessary for a member of the species to carry out its life processes
• Legislation needs to ensure that effective protections are in place for all species scientifically determined as at risk
The main purpose of laws regarding endangered species should be to ensure positive outcomes for species protection. While it is important that regulations do not create duplication or undue administrative burden, the regulations need to ensure effective protection of species scientifically identified as at risk. We strongly encourage that, as well as enforcing species protection laws, government also support voluntary efforts over and above the minimum requirements to protect species at risk.
We appreciate your consideration of our concerns and recommendations.