Comments on ERO 025-0908…

Comments on ERO 025-0908.Developing guidance on section 16 activities under the Species Conservation Act, 2025. Private Individual
Thank you for the opportunity to provide comments on the proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025. I am writing to you as a private individual and citizen of Ontario.
I strongly disagree with replacing the Endangered Species Act and am deeply disappointed at how weak and ineffectual the new Species Conservation Act is. Although this proposal is very slight on details, I have the following comments on what is presented.
Regarding the information to be included in guidance, I agree that it should included
• guidance on key concepts
• guiding principles and considerations (such as activity-related details and a species’ biological factors)
• public sources of information about protected species locations, and
• other information to support the identification and delineation of habitat as it is defined under the SCA, including habitat guidelines for specific groups of species (such as turtles, snakes, birds, fish, plants, and bats).
I would also suggest that the guidance address how to deal with habitat for species where public knowledge of their locations is a threat, whether due to the risk of poaching for food, medicine or pet trades or risk of harassment or killing (for example of snakes). I would also suggest that specific habitat guidelines be developed for guilds of mammals as well as non-vascular plants, lichens and fungi. Finally, it should include as guidance an explanation of activities likely to result in harm to individuals and destruction of habitat as well as beneficial practices.
Regarding the request for input on specific aspects of the previous policies and technical direction, this is not possible to provide without the proposal providing links to the documents in question or even a list of such documents. Similarly, despite the statement that “(t)his notice will be updated as components of the proposed guidance are available for review” has not resulted in any such update, up to and including the last day possible for comment. These two factors suggest that the request for comment on this proposal has not been issued in good faith.
I strongly encourage the government to rectify these issues before proceeding.