To Whom It May Concern, I am…

To Whom It May Concern,

I am writing to express my deep concern about the proposed replacement of Ontario’s Endangered Species Act (ESA), 2007, with the new Species Conservation Act, 2025. I urge the government to reconsider key aspects of this proposal, particularly the narrowing of habitat protections, the removal of mandatory recovery planning, and the shift of responsibility for migratory and aquatic species to federal jurisdiction.

As someone who cares deeply about Ontario species, particularly birds, I am alarmed by the proposed narrowing of the definition of “habitat.” The new, restricted definition—focusing only on nests or dens and their immediate surroundings—drastically undercuts the ecological reality that species that rely on diverse and far-reaching landscapes to survive. The 2024 State of Canada’s Birds report clearly states:
“Habitat loss threatens birds across Canada and affects migratory birds throughout their annual journeys. The destruction and degradation of habitats is driven by agricultural practices, urban development, natural resource extraction, and infrastructure.”

Birds do not only need nests to survive; they need feeding grounds, stopover sites, breeding territories, overwintering habitat, and safe corridors for migration. Narrowing habitat to a “dwelling place” fails to capture what species at risk truly need to recover.

Bird populations in Ontario and across Canada are in severe decline. According to the 2024 State of Canada’s Birds report:

Grassland birds have declined by 67% since 1970, with some species declining by more than 90%.
Shorebirds have decreased by 42%. Aerial insectivores, including swallows and flycatchers, are down by 43%.

These losses are linked directly to habitat degradation. Eliminating legal protections for habitat—especially forests, wetlands, and grasslands—is a devastating blow to species that are already in decline.

While federal legislation such as the Species at Risk Act (SARA) provides protection for some migratory birds and aquatic species, it is not designed to replace provincial responsibility. As Birds Canada has stated, the federal role is intended as a last-resort backstop—not the primary mechanism of enforcement.

The proposed change that removes provincial responsibility for these species assumes that the federal government will step in to fill the gap. In practice, federal intervention is rare and slow. This puts species like the Piping Plover, Prothonotary Warbler, and Red-headed Woodpecker at greater risk of extirpation in Ontario.

The elimination of mandatory recovery strategies and progress reviews abandons the very goal of the current ESA: species recovery. While the new legislation touts increased enforcement powers and penalties, stronger penalties don’t matter if there are no strong protections to enforce. You cannot meaningfully deter harm to species at risk if the law no longer requires meaningful protection or recovery in the first place.

As someone who deeply values Ontario’s bird life and biodiversity, I ask that the government recognize that economic growth cannot be separated from ecological stability. Species recovery is not a burden—it is a necessary investment in our future.

Birds are one of the most visible, beloved, and ecologically vital groups of wildlife in Ontario. Their survival depends on robust, enforceable habitat protections—not just voluntary stewardship. Thriving ecosystems also provide physical and emotional well-being to Ontarians but also essential economic protections in the face of increasing extreme weather events. Healthy forests, wetlands, and grasslands offer vital flood mitigation, wildfire prevention, and climate resilience, all of which contribute to the long-term stability of our communities and economy.

I strongly urge the Ministry to revise this proposal to align with science, uphold Ontario’s legal and ethical responsibility to protect biodiversity, and ensure that future generations can continue to experience the joy and wonder of birds in the wild.