• Species Classification and…

I am opposed to the proposed interim changes to the Endangered Species Act, 2007 and the proposed Species Conservation Act, 2025 for the following reasons:

• Species Classification and Listing: In addition to COSSARO, the government will have discretion to add species to or remove from the Species at Risk in Ontario (SARO) List.

COSSARO is a committee of experts appointed to make species suggestions based on scientific information. Giving the government discretion to add or remove protections for species without the need for scientific or evidence based support undermines the integrity of the Species at Risk in Ontario List and weakens the protection provided to endangered and at-risk species.

• New Habitat definition: A new habitat definition will replace the current definition in the ESA and “harass” will be removed from the prohibitions regarding harms to species.

Changes to the definition of habitat for animal species removes protections for migration and feeding habitats, both of which are important to species survival and recovery. Limiting the definition of habitat to a dwelling place does not provide sufficient protection to all required components of an ecosystem for a species to sustain life.

Limiting the definition of plant habitat to the critical root zone, only provides protection from the most severe forms of habitat impact and will likely result in eventual plant species harm through habitat loss. Critical root zone is more closely related to direct species impacts, while habitat protections must consider the wider range of direct and indirect requirements a plant needs to grow, mature, and thrive long term.

Removing “harass” from the prohibitions fails to protect species individuals from exposure to often repetitive forms of distress that may not constitute direct harm but will have substantial negative impacts to a species’ health and survival long term.

• Activity Registration: Almost all activities that currently require a permit before proceeding are anticipated to instead require registration.

While registration appears to offer species protection while increasing process efficiency, insufficient information is provided on the compliance and enforcement mechanisms that will be implemented to ensure species protection requirements are followed. Ecology is an unregulated profession, and it is not clear that proposed mitigations plans and measures stated as sufficient by consulting Ecologists will meet the ‘no negative impact test’ as defined by the Provincial Planning Statement, 2024.

• Recovery Plans: The requirement to develop a recovery strategy and management plan, government response statement, and review of progress from legislation is being removed.

Municipal, private sector, and not-for profits organizations alike rely on these resources to streamline species protection efforts across the province. Without the legislative requirement to develop these resources, a consistent and effective approach to species protection is not guaranteed. Furthermore, species specific recovery strategies inform targeted conservation and protection efforts; without these documents, opportunities to protect at-risk species and their habitats will be missed.

• Species Conservation Program: This program will increase investment in supporting voluntary activities that assist in the protection and conservation of a wider breadth of species.

Insufficient information has been provided on the details of the types of projects that can be funded by this program and who is eligible to apply for this funding. Given that participation in this program is voluntary the likelihood it will offset the negative impacts to protected species is low. However, increasing the funds available to organizations with expertise in conservation and restoration work, rather than requiring those causing the harm to invest in offsetting measures, is supported in theory.