Comment
Climate Action Newmarket-Aurora is deeply concerned that the the Developing guidance on section 16 activities in tandem with the new Species Conservation Act (SCA), as outlined under ‘Bill 5’ risk weakening the safeguards that have long protected Ontario’s most vulnerable species and habitats, despite the intent to modernize and streamline Ontario’s approach to species protection and conservation.
While efficiency in permitting is valuable, it must not come at the expense of ecological integrity, transparency, or public trust. Under the SCA, many activities that could harm species or their habitats may proceed through self-registration or broad exemptions, with limited or no public oversight under the Environmental Bill of Rights. This marks a significant shift from the former “protect first” approach of the *Endangered Species Act (ESA) toward a “balance with development” model that prioritizes speed and flexibility over science-based assessment.
Notable Outcomes:
64 “special concern” species will lose all protection;
42 aquatic or migratory species are being removed from provincial oversight on the assumption that federal laws will suffice; and
Reliance on industry-developed “conservation plans” reduces accountability and weakens independent review.
These changes risk fragmenting Ontario’s biodiversity protection framework at a time when ecosystems are already under pressure from climate change, habitat loss, and pollution. Climate resilience depends on healthy ecosystems; wetlands, forests, and grasslands that store carbon, buffer floods, and cool communities.
Weakening species protection undermines Ontario’s ability to meet both biodiversity and climate commitments, including the goals of the Canadian Net-Zero Emissions Accountability Act and Canada’s 2030 Biodiversity Strategy.
Conservation and economic development can coexist within a sounder context.
We respectfully urge the Ministry to:
Maintain clear, science-based criteria for permits rather than self-registration;
Ensure that all “special concern” species continue to benefit from precautionary habitat protection;
Integrate biodiversity conservation into Ontario’s climate adaptation and resilience planning;
Retain public notice and comment rights under the Environmental Bill of Rights for all high-risk or high-impact activities and
Commit to an independent review of the SCA’s effectiveness before it fully replaces the Endangered Species Act.
Ontario’s species and ecosystems are our natural climate allies, the foundation of resilience, clean water, and economic stability. Protecting them protects all Ontarians. Climate Action Newmarket Aurora opposes the regulation and legislation as it is currently written.
Supporting documents
Submitted October 18, 2025 10:36 AM
Comment on
Developing guidance on section 16 activities under the Species Conservation Act, 2025.
ERO number
025-0908
Comment ID
158657
Commenting on behalf of
Comment status