I reject this proposal…

I reject this proposal. There’s far too many high risks to cause irreparable damage before the government can act. With these changes expect to see a huge influx of lawsuits against the Ontario government for negligence, just like we have seen this backfire in other jurisdictions (the US). There are only examples of weak protections like in the US. Other countries have robust laws defending endangered species. Speed of economic gain is not a justification for allowing irreparable damage to habitats. I’ve highlighted the risks and impacts below:

1. Shift to a “Registration-First” Approach
• Risk: Replacing most permits with self-initiated registrations removes prior government oversight and approval before potentially harmful activities begin.
• Impact: This raises concerns that critical habitats may be degraded before provincial officers can respond, especially if proponents misinterpret or neglect regulatory requirements.

2. Discretionary Government Authority Over Species List
• Risk: The government will have discretion to add or remove species from the Protected Species in Ontario List, even after scientific classification by COSSARO.
• Impact: This undermines science-based decision-making and could politicize species protection. There is a risk that economic or development priorities may outweigh conservation needs.

3. Narrowed Definition of Habitat
• Risk: The proposed definition excludes broader ecological zones necessary for species survival, such as feeding areas, migration corridors, or seasonal foraging spaces.
• Impact: This limits habitat protection to small, well-defined areas (like nests or dens), potentially omitting critical parts of species’ life cycles and reducing habitat conservation effectiveness.

4. Removal of “Harassment” from Prohibited Activities
• Risk: Activities that disturb species (e.g., noise, human presence, light pollution) but do not physically harm them may no longer be regulated.
• Impact: This reduces protection for species highly sensitive to disruption (e.g., nesting birds), particularly in already vulnerable ecosystems.

5. Elimination of Mandatory Recovery Planning
• Risk: Removal of legislated requirements for recovery strategies, management plans, and government response statements weakens structured, accountable conservation planning.
• Impact: Without mandated recovery documents, consistent and science-based species recovery efforts may be deprioritized or underfunded.

6. Reduced Oversight for Federal Species
• Risk: Ontario will no longer regulate impacts on federally protected migratory birds and aquatic species.
• Impact: While this reduces duplication, it may leave enforcement gaps, especially if federal capacity is limited or inconsistent across regions.

7. Wind-down of Independent Oversight and Advisory Bodies
• Risk: Disbanding the Species Conservation Action Agency and the Species at Risk Program Advisory Committee removes independent oversight and public transparency.
• Impact: Concentrating power within the ministry, without institutionalized external review, reduces accountability.