ERO Submission – Re: ERO 025…

ERO Submission – Re: ERO 025-0380 – Proposed Endangered Species Act Changes

To whom it may concern,

As a long-time resident of King Township and an engaged citizen concerned about the future of Ontario’s natural heritage, I am writing to express my deep concern and strong opposition to the proposed repeal of Ontario’s Endangered Species Act, 2007 (ESA) and its replacement with the Species Conservation Act, 2025 (SCA), as outlined in ERO 025-0380.

I recognize and respect the government’s stated intention to improve efficiency, reduce duplication, and accelerate the delivery of housing and infrastructure. However, the proposed legislation does not strike the balance it claims to achieve. Instead, it significantly weakens key environmental safeguards and shifts decision-making away from transparency and science, while offering no clear evidence that it will result in better conservation outcomes.
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What’s at Stake: Beyond Permits and Paperwork

Ontario’s biodiversity is already in crisis, and our laws must reflect the urgency of this moment. Consider the Blanding’s Turtle, a threatened species found in Southern Ontario’s wetlands. This turtle relies on broad, connected habitats for survival — not just nesting sites, but travel corridors and feeding grounds.

Under the ESA, this species has received real, enforceable protections that delayed or altered developments in ecologically sensitive areas — not to stop progress, but to guide it responsibly. Under the proposed SCA, the redefined concept of “habitat” would no longer protect the areas this turtle uses to live, migrate, or feed — only its nesting site and immediate surroundings.

This shift in legal definitions may bring regulatory clarity, but it does so by abandoning ecological reality.
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Addressing the Justifications for Reform

While the proposed legislation includes reforms that may sound constructive, closer scrutiny reveals substantial risks and contradictions:

Claim: The new model is more efficient and already works.

Yes, the ministry states that a registration-first model is already used for 95% of ESA-authorized activities. But expanding this approach to almost all species-impacting activities, without case-by-case review, raises the risk of irreversible harm slipping through the cracks — especially for complex developments in sensitive landscapes. Efficiency must not come at the cost of due diligence.

Claim: The government will invest $20 million annually in voluntary conservation.

This investment is welcome — but voluntary programs cannot replace enforceable recovery planning. Species do not recover because someone may choose to restore habitat — they recover when protection is required, monitored, and backed by law.

Claim: Science remains central.

COSSARO will still classify species, but under the SCA, the Cabinet can choose not to protect them at all. This decouples science from action and opens the door to political discretion — undermining trust in the process and weakening accountability.

Claim: Recovery plans are duplicative and rigid.

While some duplication may exist with federal efforts, this is not a reason to eliminate Ontario’s recovery frameworks entirely. Instead of throwing them out, the government could focus on streamlining and improving implementation — not removing the legal duty to act on science.
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A Better Path Forward

Rather than dismantling Ontario’s Endangered Species Act, the province can achieve more efficient, responsive, and effective conservation by modernizing the current framework, not replacing it. Below are six concrete, balanced improvements that would address legitimate concerns without compromising species protection:

1. Digitize and Streamline the Permit Process

Invest in a modernized digital platform that allows for real-time application tracking, transparent communication, and habitat flagging tools. Many delays stem from administrative bottlenecks — not from the legislation itself. With better technology, Ontario can protect species and accelerate approvals.

2. Increase Staffing and Technical Capacity

Expand the number of trained ecologists, permitting officers, and compliance staff. Overloaded systems cause slowdowns and reduce review quality. More staff would reduce backlogs, improve clarity, and ensure fair and thorough decisions — a win for both proponents and biodiversity.

3. Strengthen Integration with Federal SARA Protections

Instead of removing provincial protection from federally listed species, coordinate better. Create intergovernmental protocols for joint permitting, shared habitat data, and aligned timelines to reduce redundancy without creating legal gaps.

4. Improve Transparency and Accountability in Habitat Mapping

Develop a public, science-based habitat mapping system that gives developers and the public clear, consistent information about protected areas. This increases confidence, reduces disputes, and ensures ecological integrity is factored into early planning.

5. Maintain Mandatory Recovery Planning, While Avoiding Duplication

Recovery strategies should remain a legal requirement — but their structure can be streamlined. Focus on clear, targeted, and action-oriented plans aligned with federal recovery documents when applicable. These strategies are vital roadmaps, not red tape.

6. Preserve COSSARO’s Scientific Role, and Ensure Decisions Are Actionable

COSSARO classifications should automatically trigger protection — not just sit on a list awaiting political discretion. If Cabinet overrides a listing, it should provide a public, evidence-based rationale. Science should drive action, not be sidelined by it.

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Final Appeal

This legislation, if passed as proposed, will leave Ontario with a hollowed-out conservation framework — one that is faster, yes, but less fair, less scientific, and less effective. The consequences for our wetlands, forests, and species will be long-term and likely irreversible.

We do not have to choose between a thriving economy and a healthy environment. We can — and must — achieve both. But to do so, we need a conservation system that is smart, not shallow; streamlined, not stripped down.

I urge the Ontario government to withdraw this proposal and recommit to a science-based, enforceable approach to species conservation — one that recognizes that protecting biodiversity is not a barrier to prosperity, but a condition for it.

Thank you.