Comment
The real problem was the original Bill and the Additional guidance does little or nothing to address the significant issues that have been identified by many others.
the chief problems remain:
a. removing the requirement for obtaining Indigenous consent when projects are proposed,
b. moving to a "registration" and "permit" system that appears to maintain environmental protections but that can be overridden simply by a decision maker who may have a vested interest in the outcome
c. Transparency regarding information provided on projects is not guaranteed... " Information submitted to the Registry may be made publicly available to support transparency." therefore the ability of citizens and organizations to react is hindered.
d. STating that "Registrants may be required to work with qualified professionals to develop site-specific conservation plans" essentially means that it doesn't have to happen. Again, a decision maker with a vested interest can simply override any protections.
There's a lot of "mays" in this guidance and all it essentially does is open the door for things to NOT happen
e. proposing "to exempt all permits and orders issued under the SCA from the requirements of Part II of the Environmental Bill of Rights" is another way of restricting legitimate public response to such projects.
f. restricting the SARO list to a number (plus a few) of species that are currently on the list creates a barrier to adding new species as conditions change. Loss of species and biodiversity is accelerating at an increasing pace and given that most of the development under consideration is in areas of southern and central Ontario where forests and natural spaces are already under threat, the need to react quickly and with the best science is crucial.
Thank you for considering my comments.
Submitted November 10, 2025 10:49 AM
Comment on
Developing guidance on section 16 activities under the Species Conservation Act, 2025.
ERO number
025-0908
Comment ID
170295
Commenting on behalf of
Comment status