It is difficult to trust…

It is difficult to trust that "modernization and improved user accessibility" is the intent of this proposal. In principle, these are laudable goals however, this proposal raises several serious concerns that must be addressed before any regulatory changes proceed.

1. Risk of Privatization and Outsourcing of Core Public Functions
While the proposal frames the initiative as a modernization of government services, it lacks clarity regarding whether development, deployment, or maintenance of the new licensing platform will involve private vendors or third-party contractors. Given the this government’s consistent track record of privatizing or outsourcing core public services—often with minimal transparency or accountability—this ambiguity is unacceptable.

Digital infrastructure associated with hunting and fishing licenses MUST REMAIN PUBLICLY OWNED, OPERATED, AND MAINTAINED.

Any outsourcing of development or management functions to private sector entities risks undermining public trust, increasing long-term costs, and weakening accountability for data integrity and service delivery. The government must EXPLICITLY commit to keeping these core public services in public hands, with no handover to private interests UNDER ANY CIRCUMSTANCES.

2. Concerns Regarding Public-Private Partnerships (P3s)
The language of “modernization,” “efficiency,” and “client service” suggests and even implies the potential for Public-Private Partnerships (P3s) in delivering aspects of this licensing system. P3s are well-documented to produce cost overruns, introduce inefficiencies, and reduce public oversight in essential services. The imposition of a P3 structure, especially in natural resource regulation, will introduce perverse economic incentives that place profit motives ahead of ecological stewardship and public interest, and risks entrenching long-term contractual obligations that limit future governments' flexibility.

The government MUST confirm whether any P3 or third-party vendor arrangements are planned or under consideration and include additional language in future proposals to improve full public disclosure and COMPLETE financial transperancy beyond conventional standards, in addition to environmental, and social impact reviews.

3. Lack of Free, Prior, and Informed Consent and Duty to Consult
The Provincial on behalf of the Crown, has a LEGAL duty to consult and, where appropriate, accommodate Indigenous groups when it considers policy that impacts potential or established "Aboriginal or treaty rights." This proposal has already failed to do so. As hunting, fishing, and harvesting are well-defined Rights in Section 35 of the Canada Constitution, this proposal clearly affects Indigenous Peoples’ yet nowhere in the proposal is there mention of the Crown’s Duty to Consult, upholding the principles of Free, Prior, and Informed Consent (FPIC) as articulated in the United Nations Declaration on the Rights of Indigenous Peoples Act (UNDA), which Ontario has committed to implement, in fact, there is no mention of First Nation, Inuit, or Métis people, or even Indigenous people in general.

Moving forward, as the representative of the Crown, Ontario MUST adhere to inherent and Constitutionally protected Rights to harvest wildlife and fish in accordance with their laws, historical and Modern Treaty and Self-government agreements, and obligations under Canada's UNDA, specifically Lands, territories and resources (articles 10, 26, 27, 28, 30, 32).

The digitization of licensing regimes—particularly those governing hunting and fishing—has implications not just for access, but for sovereignty and jurisdiction. Indigenous Peoples must be engaged not merely as “stakeholders” or “clients” but as RIGHTS HOLDERS. Any changes to regulatory frameworks or licensing systems that affect Indigenous harvesting must be co-developed with First Nations, Inuit, and Métis partners in accordance with Section 35 of the Constitution Act and the principles of the Truth and Reconciliation Commission's Calls to Action.

At minimum, this proposal MUST be paused until meaningful, Nation-to-Nation consultation is undertaken with Indigenous governments, organizations, and communities as required by law.

4. Failure to Consider Intersectional, Gender-Based, and Equity Impacts
The proposal’s regulatory impact statement asserts neutral-to-positive socioeconomic effects without offering any evidence of any GBA+ Analysis or intersectional equity impact assessment. This is a glaring omission.

Women, Indigenous women, 2SLGBTQ+ individuals, low-income rural residents, older adults, and — as is the case in Indigenous communities and the places where one can and does hunt— those with limited access to mobile devices or broadband internet will be disproportionately affected by a shift toward digital licensing systems. These groups are also less likely to benefit (if not directly harmed) from the proposed “mobile-first” features, and are more likely to face barriers navigating technology-driven regulatory environments (e.g. older adults, visually impaired, and Inuit in northern Ontario— who are the demographic most likely to speak neither French nor English)

Without specific mitigation plans, outreach strategies, or support mechanisms, this proposal risks reinforcing systemic inequalities and excluding historically marginalized groups from equitable participation in regulated hunting and fishing activities. A comprehensive intersectional analysis is not optional—it is a legal and moral requirement under provincial and Crown commitments to GBA+, the Ontario Human Rights Code, and the Accessible Canada Act.

In Summary:

Until the Government of Ontario can demonstrate that this proposal:

Will not result in the privatization or outsourcing of core services,

Includes transparent disclosure of any proposed P3 or private sector involvement and funds,

Fully upholds the Crown’s Duty to Consult Indigenous Peoples and obtain their Free, Prior, and Informed Consent [oops, too late], and

Undertakes a comprehensive, Co-developed intersectional analysis with clear mitigation strategies for marginalized groups,

this regulatory amendment should NOT proceed. Indigenous rights and equality provisions are inalienable rights. Public trust, ecological stewardship, and public infrastructure cannot be sacrificed in the name of administrative convenience, or this government risks legal liability.