Comment
I strongly oppose the proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025. These amendments weaken environmental and species protections, and threaten biodiversity and Ontario's ecosystems. They also threaten the public's right to have input in environmentally significant decisions.
These amendments take as a given that speeding up permit approvals is a positive thing. However, these processes should not be fast and simple. Ecosystems are complex and our environment is a precious resource. The damage companies can do to Ontario's environment and vulnerable species is long-lasting and very difficult to reverse. Therefore, permits should require time and full consideration, so that companies can be prevented from damaging our environment and driving species to extinction. Weakening species protections in the name of allowing those companies to get permits faster is not in the interests of the people of Ontario.
I am also extremely concerned by the proposal to exempt permits and orders issued under the SCA from the requirements of Part II of the EBR (Public Participation in Government Decision-Making), meaning that the public would not have the right to participate in such decision despite their environmentally significant implications.
This is part of an alarming pattern of the Ontario government attempting to limit the public's input of environmental legislation, whether by exemptions such as the one proposed, or by not providing full details of the legislation we are being asked to comment on. We have only been given broad summaries, which contain no explanation of the environmental risks and implications.
With regards to that, I would like to endorse the Legal Advocates for Nature's Defence's letter sent to the Minister of the Environment, Conservation and Parks and the Environment Commissioner on October 14, 2025 (link here: https://naturesdefence.ca/wp-content/uploads/2025/10/Letter-from-LAND-O…) and to reiterate their requests:
1) Restart the 45-day Comment Period for ERO No. 025-0909 (Proposed legislative and regulatory amendments to enable the SCA) once the text of the proposed legislative and regulatory amendments has been made publicly accessible and available online on the ERO;
2) Restart the 45-day Comment Period for ERO No. 025-0908 (Developing guidance on section 16
activities under the SCA) once the text of the Draft Guidance on section 16 activities under the
SCA has been made publicly accessible and available online;
3) Require that all proposed materials be posted on the ERO to ensure the public knows that more
information is available;
4) Ensure that the proposal details include explanations of their environmental implications; and
5) Ensure decisions on the proposals are not made until at least 45 days after all proposed
materials have been made publicly accessible and available online.
Submitted November 6, 2025 6:02 PM
Comment on
Developing guidance on section 16 activities under the Species Conservation Act, 2025.
ERO number
025-0908
Comment ID
169399
Commenting on behalf of
Comment status