The government’s proposal…

The government’s proposal for enabling the Species Conservation Act, 2025 will undermine progress on the Ontario Biodiversity Strategy and further imperil our most vulnerable species. The government proposal does not address the following concerns:
i. the far more limited definition of ‘habitat’ when compared to the ESA;
ii. the discretionary listing of species, removing an independent and evidence-based assessment approach;
iii. the offloading of responsibility for migratory birds and aquatic species to the federal government;
iv. the registration first approach; and,
v. the elimination of recovery strategies, which makes it impossible to assess, mitigate and avoid harms to species.

We are moving too quickly on this legislation. We need to look at the long term picture and prioritize the environment. I submit this as an overall objection to the replacement of the ESA with the weaker SCA and highlight the following overall recommendations for species at risk management in Ontario:
1. We need to apply a robust, evidence-based approach to defining habitat, as was done under ESA prior to the passing of Bill 5
2. We need to reduce reliance on discretionary powers related to listing and avoid exemptions to habitat protections
3. We need to ensure a listing and recovery approach based on science and Indigenous knowledge
4. We need to enforce reasonable timelines for species listing and habitat protections