On behalf of Earthroots, we…

On behalf of Earthroots, we are writing to express our deep concern and strong opposition to the proposed repeal of Ontario’s Endangered Species Act, 2007 (ESA) and its replacement with the proposed Species Conservation Act, 2025 (SCA). These changes represent a significant step backward for species-at-risk protection in Ontario.

After years of weakened implementation and neglect, Ontario’s endangered species urgently need stronger safeguards—not the dismantling of core legislative protections. The ESA was established with the understanding that identifying at-risk species is only the first step; the real responsibility lies in working actively to recover them. The proposed removal of mandatory recovery strategies, government response statements, and reviews of progress sends a clear signal that this government no longer sees species recovery as a priority.

Science-Based Decision-Making Undermined:
Perhaps most concerning is the proposal to give government the discretion to decide which species receive protection, regardless of the recommendations of the Committee on the Status of Species at Risk in Ontario (COSSARO). This echoes the failed system from before 2007, when political discretion over listings resulted in stagnation—no new species were added for decades. COSSARO was established as an independent, science-based body precisely to ensure that species assessments were insulated from political and economic pressures. Undermining its authority will set us back more than 30 years.

Redefining “Habitat” Undermines Protection:
The current ESA provides a functional and ecologically sound definition of habitat—recognizing the diverse needs of species, including feeding, migration, and rearing. By redefining habitat in the SCA as limited to nesting sites or dens and their immediate surroundings, the proposed legislation excludes vast areas essential to species survival.

For wide-ranging species like the Eastern Wolf, this change is catastrophic. These predators require extensive, interconnected habitat to hunt and thrive. The new definition also implies that only known dens would be protected—yet denning sites are incredibly difficult to locate, particularly for elusive species.

Weakening of Enforcement and Oversight:
Removing the prohibition against “harassment” of listed species opens the door to harmful disturbances of wildlife without consequence. Scaring animals away from critical areas or interfering with their normal behaviours would no longer be prohibited unless physical harm occurred. This undermines one of the most basic principles of wildlife protection.

Additionally, proposals that allow developers or resource industries to simply “register and operate” without conditions remove the ability of the province to assess or avoid cumulative impacts on species and ecosystems. And the offloading of responsibility for migratory birds and aquatic species to the federal government further weakens provincial accountability and collaboration.

Forestry and Habitat Management Conflicts:
The Crown Forest Sustainability Act currently relies on Forest Management Plans (FMPs) that reflect the ESA’s broader definition of habitat. By narrowing this definition in the new legislation, the SCA will create inconsistencies with existing forestry standards—likely prompting further pressure to lower protections in forest management.

Undermining Indigenous Rights and Environmental Justice:
The concurrent proposal to terminate the environmental assessment process for the Eagle’s Nest mine in the Ring of Fire—without consent from impacted Indigenous communities—demonstrates the government’s disregard for meaningful consultation, and environmental justice. It is especially concerning when paired with legislation that abandons recovery planning and strips habitat protections.

Conclusion:
Earthroots strongly urges your government not to proceed with ERO 025-0380. The Species Conservation Act, 2025 appears to be performative at best—stripping away the tools, accountability, and ecological principles needed to genuinely halt the decline of species at risk in Ontario.

At a time when biodiversity is in crisis, we must do better. Ontario needs bold leadership that respects science, Indigenous knowledge, and ecological integrity—not legislation that removes responsibility and weakens the province’s role in protecting life for future generations.

Sincerely,

Earthroots