I strongly oppose the…

I strongly oppose the proposed changes to the Endangered Species Act (ESA) and the creation of the Species Conservation Act (SCA), 2025, as outlined in ERO 025-0380. These changes would significantly weaken protections for species at risk in Ontario and prioritize development over conservation.
1. The shift to a registration-first system removes critical oversight. Allowing proponents to begin potentially harmful activities immediately after registration—without prior ministry review or approval—opens the door to irreversible damage to habitats and species. This eliminates the precautionary principle that underpins effective environmental protection and replaces it with a reactive approach that could fail to prevent harm before it's too late.
2. Narrowing the definition of “habitat” endangers ecosystem integrity. Reducing “habitat” to only the most specific locations where species breed, hibernate, or feed ignores the broader ecological context that supports survival. Species require complex, interconnected ecosystems—not just isolated “dwelling places”—to thrive.
3. Removing “harass” from legal protections weakens enforcement. Harassment can lead to stress, displacement, and even death for vulnerable species. Removing this term undermines our ability to protect species from harm that doesn’t involve direct destruction or killing but still has serious consequences.
4. Government discretion over species listings risks politicization. Allowing the government to decide whether or not to list species—even after COSSARO’s scientific assessment—undermines evidence-based decision-making and could delay or prevent urgently needed protections based on political or economic interests.
5. Dissolving the Species Conservation Action Agency reduces accountability. Transferring conservation funds directly to the government without an independent agency to oversee spending raises concerns about transparency and effectiveness. Independent oversight ensures that conservation funding is used appropriately and with clear accountability.
Conclusion: Ontario’s biodiversity is already under immense pressure from habitat loss, climate change, and human activity. Weakening species protections now will accelerate declines and jeopardize the ecological health of the province for future generations. I urge the Ministry to withdraw these proposals and instead strengthen the ESA with more resources, scientific integrity, and community engagement.