The proposed interim changes…

ERO number

025-0380

Comment ID

147485

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed interim changes to Ontario’s Endangered Species Act, 2007 (ESA), and the introduction of the Species Conservation Act, 2025 (SCA), represent a significant regression in environmental protection, prioritizing private economic interests over ecological integrity.

The current ESA is grounded in scientific assessments and mandates automatic protections for species listed as threatened or endangered. The proposed SCA undermines this by granting the government discretionary power to determine species protections, sidelining scientific expertise and Indigenous knowledge.

The establishment of a Species at Risk Conservation Trust allows developers to pay a fee in lieu of implementing on-the-ground conservation measures. This approach commodifies biodiversity, enabling habitat destruction as long as a financial contribution is made, which does not guarantee effective mitigation or species recovery.

The redefinition of 'habitat' to include only breeding and hibernation sites neglects other critical areas necessary for species survival, such as foraging and migration corridors. This narrow scope fails to provide comprehensive protection for species throughout their life cycles.

Transitioning to a 'registration-first' approach permits developers to proceed with activities impacting species at risk without prior approval, relying on self-assessment and compliance. This diminishes regulatory oversight and increases the risk of non-compliance, potentially leading to irreversible ecological damage.

When policymakers enact legislation that knowingly compromises environmental integrity for personal or associated economic gain, it constitutes a breach of public trust and a form of corruption. Such actions not only endanger biodiversity but also undermine democratic principles and the rule of law.

Criminalizing these actions would serve as a deterrent against the exploitation of public office for private benefit. It would reinforce the accountability of public officials and ensure that policy decisions are made in the public interest, preserving ecological and social well-being for current and future generations.