This comment is submitted on…

This comment is submitted on behalf of the Huron Stewardship Council. The Huron Stewardship Council (HSC) is a not-for-profit, volunteer organization that works to conserve our natural spaces in Huron County for future generations through wise and attentive management.

Huron County is the most agriculturally productive county in Ontario. The County stretches along 100 km of Lake Huron shoreline in southwest Ontario. In the rivers and valleys of this agricultural landscape is a thriving rural and natural environment, one that is occupied by a variety of Species at Risk.

Re. ERO 025-0909 Proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025

We urge you to immediately forgo the new regulations proposed to bring the Species Conservation Act, 2025 into force, replacing the Endangered Species Act, 2007.

The proposed changes will undercut critical regulations that protect many of Ontario’s most vulnerable plants and animals. All of the proposed amendments are intended to speed up or reduce restrictions on activities that harm those species.

The proposal to redefine the definition of “habitat” will effectively remove protections from areas needed in processes critical to a species survival, such as foraging, and does not consider the entirety of a species home range, resulting in potential loss of useful habitat for our species at risk. Furthermore, habitat, such as field corridors, help build resilience to environmental changes, like flooding and climate change effects. These habitats are being actively used and facilitate safe and effective dispersal.

The proposed repeal of the Endangered Species Act (2007) eliminates the requirement for a provincial recovery strategy, limiting recovery efforts to the national level excluding species only listed provincially. Under these changes, only federally listed species would have a recovery strategy.

Under the proposed Species Conservation Act (2025), statuses of species at risk are at the discretion of the Lieutenant Governor in Council and Minister, regardless of current data and scientific recommendations. This may result in the loss of status for certain species at risk in order to streamline and advance proposed projects.

Under the proposed Species Conservation Act (2025), the Lieutenant Governor in Council as well as the Minister can appoint COSSARO members under a broad spectrum of community knowledge, rather than remaining as an independent authority.

Under enactment of the Special Economic Zones Act (2025), the creation of “Special Economic Zones” exempts certain parties from the requirements of any regulations, specific acts, or municipal bylaws that would otherwise apply. This allows the Cabinet to grant exemptions at any location on any basis. This lack of transparency and regulation application may result in the exploitation of species at risk and their environments.

Your ministry should not proceed with the proposed regulatory amendments, but rather withdraw, amend, or reconsider Bill 5 in its current form.

Thank you for your consideration.