Re: ERO 025-0380 – Proposed…

Re: ERO 025-0380 – Proposed interim changes to the Endangered Species Act (ESA), 2007 and a proposal for the Species Conservation Act (SCA), 2025

I am writing today to urge the Government of Ontario to abandon plans to replace the ESA, 2007 with the proposed SCA.

I understand that the current political climate puts Canada’s provincial and federal governments in a precarious position. I certainly applaud efforts to ensure an independent and resilient economy that is insulated from foreign economic threats. The plan, however, to strip away protections for endangered species to fast-track development and mining in Ontario is short-sighted and will irreparably impact species at risk in Ontario, threaten biodiversity and ultimately trickle down to economic impacts that in the long run are likely to exceed any economic gains.

Biodiversity is inextricably linked to human health, climate stability, and the economy. For example, maintaining healthy ecosystems by protecting species at risk and biodiversity provides ecosystems services (e.g. clean air/water, food security, climate resilience, pharmaceuticals, recreation and tourism, improved mental health, and cultural/spiritual gratification, etc.) that are critical for human well-being. The current proposal has several changes that threaten, rather than protect, biodiversity, and I urge the government to reconsider these changes. Although I am concerned for how these changes will impact all species at risk in Ontario, I am particularly concerned for the recovery of eastern wolves (Canis cf. sp. lycaon), a threatened species under Canada’s Species at Risk Act (SARA) and Ontario’s ESA, because of their wide home range and their importance as a top predator and ecosystem regulator.

Main Issues with ERO 025-0380

Species Classification and Listing:
To give the government discretion to add and remove species from formal listing is dangerous. Politicians are not scientists and have no expertise or background knowledge to make those decisions. Listing and de-listing species must reside with a scientific advisory board that is at arms-length and insulated from the government (e.g. the Committee on the Status of Species at Risk in Ontario - COSSARO) and follows established process and assessment according to the best available science. By proposing to give politicians the veto power over which species are at risk of extinction and which are not, you declare that you do not appreciate science, and you do not trust scientists who have, in many cases, dedicated their careers to wildlife conservation. The veto power needs to be removed – otherwise it leaves COSSARO as an agency with no teeth.

Redefining Protections:
The proposed changes to the definition of “habitat” is a problem for species like eastern wolves that do not simply reside in a single place – they have territories that are hundreds of square kilometers (which they need for hunting) and individuals need to disperse (often over hundreds of kilometers) to establish new territories and find potential mates. The current proposed changes simply do not capture what habitat is required for eastern wolf life history traits and recovery.
Furthermore, it is not clear why the government is proposing to remove the word “harass” from the species protections when this is clearly part of the federal government SARA language. For wild animals, survival is largely about energetics – energy in and energy expended. When these animals are harassed, they expend unnecessary energy that is a threat to their survival. I encourage the government to reconsider both the “habitat” and “harass” proposed amendments.

Recovery Plans and Documents:
The proposal to eliminate the need for recovery strategies and management plans is poorly thought-out. There needs to be a clear and scientifically sound basis for moving forward with species protections and recovery to avoid future loss of biodiversity.

Registration-first Approach:
The proposal for proponents to start development projects by simply registering their plans is unacceptable and is a major threat to biodiversity. I encourage the government to more fully support and streamline their permitting process rather than put the decision making in the hands of developers and corporations.

At its inception, Ontario’s ESA, 2007 was considered by the international community to be the gold standard of species at risk policy. Since then, it has been dismantled to become a policy that prioritizes industry and short-term profit over long-term protection of nature and the environment. I can see that any policy may need improved efficiencies along the way, and I am not opposed to more streamlined reviews for certain industry and development with the focus on consensus for how to ensure economic resiliency but still maintain powerful protections for species at risk. The current proposal of changes, however, is unlikely to do either in the long-term and I strongly encourage the government to abandon the proposed changes – particularly those listed above.

I appreciate your time and consideration in this matter.