As an Environmental…

As an Environmental Technologist with the Department of National Defence, I strongly oppose this proposal due to the serious ecological risks it poses to Ontario’s species and habitats.

The rationale that removing federally listed species from Ontario’s protection “avoids duplication” is fundamentally flawed. Federal protections under the Species at Risk Act (SARA) apply primarily to federal lands and undertakings, such as DND properties, national parks, and fisheries. However, most of Ontario’s habitat exists on provincial Crown or private land, areas where SARA protections rarely apply in practice. By excluding aquatic and migratory species from the provincial “Protected Species in Ontario List,” Ontario would, in effect, remove protection from the majority of the landscapes these species depend on.

In my professional work, I have seen firsthand how species at risk that benefit from protection on federal lands become vulnerable once they move beyond those boundaries. The assumption that federal coverage is sufficient is incorrect. It leaves critical habitat unprotected and creates regulatory gaps that directly endanger wildlife.

From an environmental management perspective, this proposal will make it easier to alter or destroy habitats that are essential for species recovery and ecosystem stability. It will also undermine science-based environmental assessments and monitoring, which rely on the provincial species at risk list to identify and mitigate potential impacts.

Furthermore, the shift from automatic to discretionary listing of species identified by COSSARO introduces unnecessary political interference into what should remain an objective, science-driven process.

I urge the Ministry to:

- Maintain all currently listed species under provincial protection, including those also covered federally;

- Retain automatic listing of species identified by COSSARO; and

- Preserve strong, enforceable habitat protections across both provincial Crown and private lands.

Ontario should not weaken species protection under the guise of efficiency. The proposed changes will create regulatory blind spots and further accelerate biodiversity loss in the province.

Remember that each species, no matter how small, is a thread. How can we possibly hope to maintain the fabric of our beautiful province if we unravel it piece by piece?