I am in opposition to the…

I am in opposition to the proposed Species Conservation Act (CSA), which would repeal and replace Ontario’s Endangered Species Act. This proposal represents a significant weakening of protections for Ontario’s most vulnerable species and ecosystems.

The CSA’s definition of “habitat” is extremely limited. It restricts habitat to a “dwelling place” such as a den or nest and the immediate surrounding area. This narrow view ignores the ecological reality that species rely on a much broader range of space for survival. Animals do not live solely within their nests or dens and the small area around them—they travel to forage, find mates, access water, and gather materials to build habitats. By excluding these essential areas, the CSA leaves critical parts of species’ life cycles unprotected, making it easier for harmful activities to proceed and harder for species to survive.

The proposed change in the definition of prohibited activities also narrows the scope of protection. By limiting prohibitions to actions that “kill, harm, capture, or take” a species, the CSA fails to account for indirect but equally damaging impacts such as habitat degradation, pollution, and disruption of food sources. These changes shift the focus away from protecting the ecosystems that species depend on and toward only preventing direct, visible harm—an approach that is insufficient for meaningful conservation.

Ontario’s dual protection system, with both federal and provincial safeguards, is essential. The province often has more localized knowledge of species health and habitat conditions. If the federal Species at Risk Act (SARA) were ever weakened or repealed, and the CSA replaced the ESA, Ontario’s species could be left with no effective protection. Maintaining strong provincial legislation is a necessary safeguard.

The CSA also removes critical accountability mechanisms. It eliminates the requirement for recovery strategies, government response statements, and progress reviews. These tools are essential for transparency, long-term planning, and ensuring that conservation efforts are effective. Replacing them with discretionary “conservation guidance” from the ministry—an entity that is not independent from political influence—undermines science-based decision-making and public trust.

The proposed $20 million investment in community-based conservation is not a substitute for strong legal protections. While community involvement is important, shifting responsibility to underfunded, volunteer-driven organizations is not a viable replacement for government enforcement. This funding does not compensate for the loss of legal safeguards and accountability structures.

The removal of the ESA’s advisory committee is another step backward. This committee provides expert guidance on stewardship, education, and policy. Eliminating it silences independent voices and reduces opportunities for informed, science-based conservation planning.

The most alarming change is the shift to a “registration-first” permitting system. This would allow potentially harmful activities to proceed immediately after online registration, without requiring any upfront demonstration of compliance with species protection measures. This opens the door to unchecked harm. Even if a proponent is later found to have violated the law, the damage—potentially including extinction—cannot be undone.

The CSA weakens protections, removes oversight, and prioritizes development over conservation. I demand this bill to be withdrawn.