Comment
I strongly oppose the proposed interim changes to the Endangered Species Act, 2007 and the introduction of the Species Conservation Act, 2025.
One of the most concerning aspects is the redefinition of “habitat.” By narrowing the definition to only the immediate area around nests, dens, or critical root zones, the proposal ignores the broader ecosystems species depend on for foraging, movement, and shelter. This limited view does not align with established ecological science and will lead to the fragmentation and degradation of habitats essential to species survival. Such a shift could accelerate species decline rather than protect them.
Equally troubling is the move to a registration-first system where proponents can begin activities immediately after submitting an online registration. This eliminates the crucial review step where ministry experts would evaluate the potential impacts on species. Without adequate oversight, this approach opens the door to abuse, unintentional harm, and even fraudulent registrations—greatly weakening enforcement and accountability.
Additionally, giving the government discretion to add or remove species from the Species at Risk in Ontario (SARO) List without requiring adherence to COSSARO’s scientific assessments is deeply problematic. It politicizes species protection and leaves critical conservation decisions vulnerable to lobbying and short-term economic pressures, rather than ecological realities.
These changes do not represent a balanced approach—they prioritize convenience and deregulation over meaningful conservation. I urge the government to halt these amendments and engage in genuine consultation rooted in science and long-term species survival.
Submitted April 18, 2025 7:16 PM
Comment on
Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025
ERO number
025-0380
Comment ID
126098
Commenting on behalf of
Comment status