I am writing to express my…

I am writing to express my profound concerns regarding the proposed interim changes to the Endangered Species Act, 2007, and the proposal for the Species Conservation Act, 2025, as outlined in ERO number 025-0380. While the stated aim of streamlining processes and reducing costs is noted, the potential negative consequences for Ontario's biodiversity are deeply troubling and warrant serious reconsideration.

The proposed shift towards a "registration-first" approach for the majority of activities currently requiring permits raises significant concerns about the level of environmental oversight. Eliminating the need for individualized environmental impact assessments in favor of a system reliant on proponents adhering to potentially broad regulations risks overlooking complex and cumulative impacts that standardized rules may not adequately address. This streamlined process should not come at the expense of thorough environmental scrutiny, which is essential for safeguarding vulnerable species and their habitats.

Furthermore, the proposed redefinition of "habitat" appears to significantly narrow the scope of protection, focusing primarily on immediate dwelling places. This revised definition disregards the crucial surrounding areas that species depend on for foraging, dispersal, and other essential life processes. Such a restricted definition could lead to habitat degradation and fragmentation, undermining the very foundation of species survival, even if registered activities avoid direct impact on nests or dens.

The introduction of government discretion in adding or removing species from the protected list is also a cause for concern. While the continued role of COSSARO for scientific assessment is acknowledged, granting the government the authority to override these assessments based on socio-economic considerations introduces the potential for political influence to compromise the protection of at-risk species. Decisions regarding the conservation status of species must remain firmly rooted in scientific evidence, free from undue external pressures.
The removal of the legislated requirements for recovery strategies, management plans, government response statements, and progress reviews weakens the framework for long-term species recovery and reduces government accountability. While flexibility in conservation efforts may be desirable, abandoning the systematic planning and reporting mechanisms currently in place risks a less comprehensive and ultimately less effective approach to ensuring the survival of endangered and threatened species.

While the proposed increase in funding for the Species Conservation Program is acknowledged, relying on voluntary initiatives as a primary mechanism for species protection is insufficient. Regulatory protections provide a necessary baseline for preventing harm, and voluntary measures, while valuable, cannot be relied upon to fully compensate for potentially weakened legal safeguards. Furthermore, the decision to wind down the Species Conservation Action Agency eliminates a dedicated funding source and specialized expertise focused solely on species recovery, potentially diluting the resources and capacity available for effective conservation.
Finally, the removal of the prohibition against "harassing" species is a step backward in ensuring their well-being. Disturbance during critical life stages can significantly impact breeding, feeding, and overall survival, even if direct harm to habitat as narrowly defined is avoided.

In conclusion, while the stated goals of efficiency and reduced costs are understandable, the proposed changes to the Endangered Species Act and the introduction of the Species Conservation Act as currently outlined risk a significant weakening of environmental protection in Ontario. Prioritizing streamlined processes over thorough environmental assessment and legally mandated recovery efforts could lead to irreversible biodiversity loss. I urge the provincial government to reconsider these proposed changes and prioritize a strong, scientifically sound, and accountable framework for the protection of Ontario's endangered and threatened