I am writing to express…

I am writing to express strong opposition to the proposed amendments to the Endangered Species Act (ESA) and the implementation of the new Species Conservation Act (SCA), 2025. While I recognize the importance of balancing environmental and economic goals, these changes represent a significant step backward in the protection and recovery of Ontario’s most vulnerable species.

Several elements of this proposal are particularly troubling:

Weakened Purpose of the ESA:
Amending the ESA’s purpose to explicitly consider “social and economic” factors risks undermining its foundational goal of protecting species at risk and their habitats. Conservation should not be conditional on economic convenience — it should be a guiding principle, not a secondary consideration.

Government Discretion Over Species Listings:
Granting the government the power to add or remove species from the Species at Risk in Ontario (SARO) list — even if science-based assessments continue — politicizes what should be a scientific and transparent process. This introduces unnecessary uncertainty and opens the door to decisions driven by short-term interests rather than long-term ecological health.

Redefinition of Habitat and Removal of ‘Harassment’ Provisions:
Changing the legal definition of “habitat” and eliminating “harass” from prohibited harms significantly narrows the scope of protection. This weakens our ability to shield species from disturbance and degradation that can have long-term negative impacts on survival and recovery.

Removal of Recovery Strategy Requirements:
Eliminating the legal requirement to develop recovery strategies for listed species is alarming. Recovery strategies are a critical tool for guiding conservation action and ensuring that species don’t just persist, but begin to recover and thrive.

Loss of Funding Flexibility and Oversight Bodies:
Discontinuing the option to contribute to the Species at Risk Conservation Fund may limit conservation outcomes, particularly for smaller proponents who may lack the capacity for direct on-the-ground action. Additionally, the removal of the Species Conservation Action Agency and Advisory Committee diminishes transparency and stakeholder engagement at a time when more oversight is needed, not less.

Jurisdictional Gaps for Migratory and Aquatic Species:
Ceasing provincial permit requirements for migratory birds and aquatic species risks creating enforcement and accountability gaps, particularly if federal protections are not implemented robustly on the ground in Ontario.

In conclusion, while I support the goal of improving the effectiveness of conservation in Ontario, these proposals do not achieve that aim. Instead, they reduce protections, remove accountability, and prioritize deregulation over ecological responsibility. I urge the Government of Ontario to reconsider these changes and uphold a strong, science-based approach to species protection that reflects our shared responsibility to preserve Ontario’s biodiversity for future generations.