The proposed definition of…

The proposed definition of habitat lacks clarity—many species require significantly more space than just a dwelling and its immediate surroundings to carry out necessary processes. Why has the decision been made that "harassment" of a species does not require a permit? This raises serious concerns about species protection throughout the development process.

Eliminating the requirement for recovery plans and supporting documentation for Ontario’s Species at Risk undermines the foundation of science-based conservation. These materials are essential for understanding species’ needs and informing protection measures. It is important to note that not all species listed federally under SARA are recognized as at risk in Ontario. Without publicly available recovery strategies, how will developers receive clear guidance or be held accountable for their impact on species at risk?

Under the new Species Conservation Program, there appears to be no legislative requirement to protect species, in contrast to the obligations set out in the Endangered Species Act, 2007. This shift seems not only inadequate but regressive. What, if any, meaningful incentives exist for developers to voluntarily engage with this program? The lack of enforceable commitments calls into question the government’s true dedication to species conservation.

The absence of a Species at Risk advisory committee further limits transparency and the ability for stakeholders, including industry, to seek clarification or raise concerns.

There also appears to be a contradiction in the proposed registration-first model. If development can begin immediately upon registration, how can species presence be verified in time to ensure their protection? This approach seems to preclude proactive enforcement.

Finally, under what criteria can the Ontario government override COSSARO's determinations and delist species identified as at risk? This raises serious concerns about the erosion of science-based decision-making in favor of potentially political or economic considerations.