To Whom It May Concern, I am…

To Whom It May Concern,

I am writing in response to the recently proposed changes to the Endangered Species Act and the proposed Species Conservation Act. I am a biologist and I work with species at risk. I am very concerned that protection for species at risk will be reduced, which could be detrimental to populations.

1. Shifting from permitting to a registration-only process will speed up habitat loss, which is already a major factor for population declines of numerous species. Permitting is important to assess potential impacts on species at risk before impacts happen. With a registration-only process, any activity will move forward, regardless of whether the activity may be harmful to species at risk. Restoring habitat is more expensive and less effective than preserving habitat.

2. The redefinition of habitat is completely inadequate. The habitat of a species cannot be reduced to an occupied dwelling place or to the critical root zone. Please consult specialists when working on a definition for habitat.

3. Removing the concept of “harass” is problematic, especially in combination with the new definition of habitat. According to the proposed changes, an animal species at risk could be harassed at its occupied dwelling place, which could lead to the animal abandoning its dwelling place. The dwelling place would no longer be occupied, hence, it would be legally permitted to be destroyed. Redefining habitat and removing the concept of “harass” diminishes the protection for species at risk.

4. Why are the Species Conservation Action Agency and the Species Conservation Fund supposed to be wound down? They were just established in 2021! It seems incredibly inefficient to me.

5. I agree with establishing a framework and setting clear expectations and rules. However, it is unclear what these expectations and rules are, which seems to contradict the intention.

6. I agree with supporting voluntary initiatives that protect and conserve species. However, it is inconsiderate to make the fate of species reliant on voluntary initiatives. Adequate protection needs to be legally binding.

Further, I am also concerned about the rights of Ontarians and, in particular, indigenous peoples. The proposed changes are aimed to streamline development, but I fear that there will not be adequate time and effort spent to consult the communities in which development projects are occurring. It is a shame that these significant changes are being pushed through quietly, while the attention of the public is on the recent federal election and international issues.

I hope these changes will be reconsidered and that my comments will be helpful. I hope the Ontario government takes the interests of the public into account and puts people and the environment before business and development.

Sincerely, HK