I do not support the…

I do not support the proposed interim changes to the Endangered Species Act, 2007 and the proposal for its replacement with the Species Conservation Act, 2025

Population health (ours) is dependent on Planetary health (our natural environment including the biodiverse web of life and ecosystems that sustain us). The provisions in the replacement of the ESA with the SCA demonstrate an ignorance of that reality.

Replacing scientific expertise with ministerial discretion is misguided and short sighted. Politicians should not have discretion to remove species from the list of protected species. This is a determination which requires an understanding of biologic and environmental processes and should not be left to an individual whose objectives may run counter to conservation. The discretionary removal of species by the government should be removed from the proposed bill.

The 'definition of habitat' proposed ignores the reality that species have complex needs that extend beyond roots in the ground or a hole in a tree. Vascular plants live in communities supported by myriad other species and foraging species don't find food in the confines of their dens, just as we cannot thrive in the confines of our shelter without regard for access to the other necessities of life. The only clarity that these changes will ensure is the further loss of species. The definition of habitat needs to recognize that species live in ecosystems. It is not acceptable to simplify the definition of habitat as proposed.

The registration first approach with yet to be determined regulations is akin to shooting first and asking questions later. The removal of important safeguards in the Endangered Species Act clearly indicates an intent to accept species decline as an inevitable cost of doing business, ignoring the hidden cost of those actions. If the government is truly committed to species conservation, these regulations would be developed prior to implementing any proposed changes.

The proposed changes to the ESA and its replacement with the SCA is not a 'reasonable, balanced approach to protecting species in Ontario'. It is an attempt to gut important protections for species at risk ignoring the fact that we already have a biodiversity crisis and are borrowing from our children.

We will not unleash our economy by disregarding our environment. The provisions outlined in the Unleashing our Economy Act, 2025 demonstrate a lack of understanding of the value of environmental services and our dependence on biodiversity and ecosystem health for our own well-being. A robust economy is built by a thriving society living in a resilient and healthy environment. There is no economy without those foundational supports.

Thank-you for your consideration.