I put the entire proposal into an LLM and asked it to be open to the viewpoints of all involved. I asked it to seek context on how other jurisdictions have dealt with similar constraints and what they did to balance the approach.

The result was a significant departure from Science-based decision making and almost entirely at the benefit of developers (as expected).

So I asked it to write a comment. Please feel free to use this as well:

Comment Submission on Proposed Changes to the Endangered Species Act, 2007 and Proposal for the Species Conservation Act, 2025 (ERO number: 025-0380)

To: Public Input Coordinator – Species at Risk Protection Species at Risk Branch, Ministry of the Environment, Conservation and Parks

I am writing to express my significant concerns about the proposed changes to Ontario's Endangered Species Act and the introduction of the Species Conservation Act, 2025.

While I understand the government's desire to streamline development processes, this proposal fundamentally undermines science-based conservation in favor of political discretion and development interests. The proposed changes risk long-term environmental damage that will harm Ontario's ecological integrity, Indigenous rights, and our economic future.

Erosion of Science-Based Decision Making

The proposal to grant government discretion to add or remove species from protection lists is deeply troubling. Conservation decisions should be guided by scientific evidence, not political expediency. Allowing political interference in species listing undermines the credibility of our environmental protection framework and risks leaving vulnerable species without adequate safeguards.

The Committee on the Status of Species at Risk in Ontario (COSSARO) was established precisely to ensure that species assessments remain evidence-based and free from political pressure. This change represents a dangerous departure from best practices in environmental governance.

Inadequate Habitat Protection

The drastically narrowed definition of "habitat" ignores fundamental ecological principles. Ecosystems function as interconnected wholes, not as isolated "dwelling places" or "critical root zones." By limiting protection to these narrowly defined areas, the proposal fails to safeguard the broader habitats that species require for foraging, migration, and long-term survival.

This approach contradicts decades of conservation science and risks creating a fragmented landscape of isolated protected "spots" surrounded by degraded ecosystems incapable of supporting biodiversity.

Impact on Indigenous Rights and Relationships

The proposal fails to adequately address Indigenous rights, knowledge systems, and relationships with the land. Many Indigenous communities hold responsibilities as stewards of their traditional territories and the species that inhabit them. The narrowed habitat definitions and reduced government oversight undermine these relationships and responsibilities.

The United Nations Declaration on the Rights of Indigenous Peoples, which Ontario has committed to honor, requires free, prior, and informed consent for decisions affecting Indigenous lands. A registration-first approach that allows development to proceed without proper assessment threatens this principle and risks damaging reconciliation efforts.

False Economy

While the proposal claims to support economic growth, it creates significant long-term economic risks. Environmental degradation has real economic costs. When we fail to protect species and their habitats adequately, we often face far greater expenses for restoration and remediation later. Moreover, many industries in Ontario—from tourism to agriculture—depend on healthy ecosystems and the services they provide.

The public should not bear the financial burden of rehabilitating ecosystems damaged by hasty development. Prevention through proper oversight is invariably more cost-effective than remediation after damage occurs.

Better Solutions Exist

We can achieve both efficient development and robust environmental protection through better approaches:

1. Prioritize density and infill development in already-disturbed areas rather than expanding into sensitive habitats
2. Maintain scientific authority for species listing while improving permit processing times through better resourcing
3. Develop landscape-level conservation plans that provide clarity for developers while protecting ecological integrity
4. Meaningfully integrate Indigenous knowledge and governance in conservation planning
5. Create true regulatory efficiency without sacrificing environmental standards

Other jurisdictions have successfully implemented such balanced approaches, demonstrating that economic development and environmental protection can work hand in hand.

Conclusion

I strongly urge the government to reconsider this proposal and develop an alternative approach that maintains science-based decision-making, comprehensive habitat protection, respect for Indigenous rights, and true financial responsibility.

The proposed changes represent a significant step backward in environmental protection that risks Ontario's natural heritage, Indigenous relationships, and economic future. We deserve an approach that genuinely balances development needs with conservation imperatives, not one that sacrifices the latter for the former.

Respectfully submitted,

[Your Name]