I am writing to express…

I am writing to express strong opposition to the proposed amendments under ERO 025-0380, which seek to modify the regulatory framework governing wildlife custodians (rehabilitators) and falconers in Ontario.

Although framed as a measure to improve administrative efficiency, the proposal would in fact undermine essential safeguards for wildlife welfare, public trust, and conservation outcomes. It does so by transferring critical regulatory provisions from the Fish and Wildlife Conservation Act into discretionary licensing conditions under ministerial authority, thereby bypassing necessary legislative scrutiny and public consultation processes.

Wildlife rehabilitation is a highly specialized field requiring rigorous training, facility standards, species-specific knowledge, and ethical decision-making to ensure appropriate outcomes for injured, orphaned, or displaced wildlife. Any reduction in oversight or professional requirements — even under the guise of "streamlining" — would significantly increase the risks of poor animal welfare outcomes, failed rehabilitations, disease transmission, and inappropriate releases.

Similarly, the relaxation of falconry regulations, particularly concerning the capture and possession of raptors, raises serious conservation and animal welfare concerns. Raptors serve crucial ecological roles as apex predators, and any dilution of regulatory controls risks encouraging commodification and unsustainable practices that are inconsistent with Ontario’s broader biodiversity commitments.

Furthermore, the proposed structural change — allowing the Minister to dictate substantive licensing requirements without full legislative amendment — represents a concerning erosion of transparency, accountability, and public oversight. Wildlife are a shared public resource, and decisions affecting their stewardship should remain subject to the highest standards of democratic governance, scientific review, and public input.

If efficiency is indeed the government’s goal, efforts should be directed toward supporting capacity-building within the wildlife rehabilitation sector, strengthening standards through consultation with veterinary and ecological experts, and investing in enforcement resources — not dismantling regulatory frameworks that protect vulnerable species and public trust.

For these reasons, I urge the Ministry to withdraw this proposal in its current form and to recommit to evidence-based, transparent, and conservation-oriented wildlife governance.