Response to Proposed…

Response to Proposed Amendments to Ontario’s Endangered Species Legislation
To: Ministry of the Environment, Conservation and Parks
RE: Proposal to amend the Endangered Species Act, 2007 and introduce the Species Conservation Act, 2025

I am writing to express serious concerns regarding the proposed changes to Ontario’s species-at-risk framework as outlined in the Protect Ontario by Unleashing our Economy Act, 2025 and the proposed Species Conservation Act, 2025.

While I support efforts to improve efficiency and provide regulatory clarity, the changes being proposed risk fundamentally weakening Ontario’s commitment to biodiversity protection. In particular, I am concerned that the new approach shifts the focus away from science-based species conservation in favor of economic expediency.

1. Discretionary Species Listings Undermine Scientific Integrity
Giving the government discretion to decide which species are added or removed from the Protected Species in Ontario List—despite scientific assessments by COSSARO—undermines the credibility and independence of Ontario’s species-at-risk process. Decisions about species protection must remain firmly grounded in science, not political or economic considerations.

2. Registration-First Approach Reduces Oversight and Increases Risk
Replacing permits with an immediate registration system for most activities removes a critical layer of oversight. While this may streamline approvals, it allows potentially harmful activities to proceed before impacts on species or habitats are fully assessed or mitigated. A one-size-fits-all approach does not account for complex ecological realities.

3. Narrowed Habitat Definition Weakens Species Recovery
The proposed redefinition of “habitat” excludes important ecosystem components such as migration corridors, feeding areas, and broader landscapes that many species depend on. This risks fragmenting habitat protections and undermining recovery efforts.

4. Elimination of Recovery Planning Removes Transparency and Accountability
Removing the legislative requirement to produce recovery strategies, response statements, and progress reviews eliminates essential planning tools that guide species recovery efforts and hold the government accountable. Recovery planning is not bureaucratic redundancy—it is foundational to effective conservation.

5. Removal of “Harass” from Protections Creates Enforcement Gaps
The removal of “harassment” from species protections introduces a serious loophole. Chronic stressors or repeated disturbances that fall short of direct harm can still jeopardize species health and reproductive success. This term should be retained to ensure comprehensive protection.

6. Loss of Advisory Committees Limits Public and Indigenous Engagement
The proposal removes the explicit ability to establish advisory committees, including the Species at Risk Program Advisory Committee. This reduces opportunities for inclusive dialogue and diminishes Indigenous and public voices in conservation policy.

7. Economic Growth as a Stated Purpose Undermines Conservation Goals
Including “sustainable economic growth” in the purpose of the legislation risks subordinating conservation to development. While balance is important, biodiversity protection should remain the primary goal of species-at-risk legislation.

Recommendations:
-Retain automatic legal protection for species listed by COSSARO.

-Preserve a meaningful permitting system that requires review of activities before they proceed.

-Maintain a broad, science-based definition of habitat.

-Restore mandatory recovery planning requirements.

-Keep “harass” as a prohibited activity.

-Ensure Indigenous rights and perspectives are embedded in decision-making processes.

-Restore the ability to establish expert and public advisory committees.

-Reframe the legislation’s purpose to prioritize biodiversity protection, with economic considerations secondary and supportive.

Ontario has a legal and moral obligation to safeguard its biodiversity for future generations. These proposed changes risk eroding that commitment and placing species further at risk. I urge the Ministry to reconsider the direction of this proposal and work collaboratively with scientists, Indigenous communities, and the public to ensure Ontario’s conservation laws remain strong, credible, and effective.