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I am submitting this comment to express strong opposition to the proposed guidance and implementation framework under the Species Conservation Act, 2025 (SCA). The approach outlined represents a serious weakening of protections for Ontario's species at risk and fundamentally undermines the province’s obligations to biodiversity conservation, ecological integrity, and intergenerational responsibility. I highlight the following key issues:

1.Definition of Habitat is Scientifically Inadequate and Irresponsible
The SCA defines habitat for animal species only as an active dwelling place and the immediate area around it. This definition ignores decades of ecological science demonstrating that habitat includes all areas required for feeding, dispersal, migration, overwintering, resting, and breeding, not just a nest or den. It also explicitly excludes historical or potential habitat needed for species recovery. This exclusion makes recovery impossible, particularly for wide-ranging species and those requiring seasonal habitat mosaics. Fragmenting habitat into isolated “nests/dens only” protection zones will accelerate extirpations.

2.Registration and Permitting Systems Allow Legalized Harm to At-Risk Species
The Act enables developers to self-register or obtain permits to carry out activities that harm species or destroy habitat. This framework prioritizes development efficiency over ecological responsibility and effectively legalizes the avoidable degradation of critical ecosystems. It is inconsistent with Ontario’s constitutional, ethical, and international responsibilities to safeguard biodiversity, and reconciliation-aligned stewardship values held by Indigenous Nations whose traditional territories include protecting these species and landscapes.

Ontario has already witnessed the failure of “permit-to-harm” and offset-based systems in wetlands and woodlands, where promised “compensation” has not prevented long-term ecological loss. Extending this approach to species at risk will guarantee further habitat destruction before adequate review, exacerbate cumulative effects, and create enforcement gaps that cannot be retroactively repaired once species populations decline or disappear.

Allowing environmental harm through administrative shortcuts does not create stable economic conditions—it externalizes ecological costs, increases climate-related risk, and undermines industries that depend on healthy ecosystems, including agriculture, forestry, fisheries, tourism, and recreation. The long-term prosperity of Ontario depends on resilient landscapes, functioning ecosystems, and thriving wildlife populations, not on short-term development pressure. Policies that accelerate species loss are not pro-growth—they are anti-future, risking biodiversity collapse, community well-being, and the cultural and natural heritage Ontarians value and are responsible for passing to future generations.

3.Ministerial Power to Influence COSSARO Decisions Threatens Scientific Integrity
The Act allows political intervention into independent scientific assessments. Species classification must remain independent, science-driven, and free from political and industry pressure. Allowing ministerial influence undermines scientific rigour, transparency, public trust, and recovery outcomes.

4.Loss of Provincial Protection for Migratory Birds and Aquatic Species
The Act removes provincial responsibility when species are federally listed, creating a dangerous regulatory gap for migratory birds and aquatic species. While federal laws such as the Migratory Birds Convention Act and the Species at Risk Act provide baseline protections, they do not adequately address provincial land-use decision-making, nor do they consistently apply to activities occurring on private or provincial Crown lands — the very landscapes where habitat loss, fragmentation, and industrial development pressures are most severe in Ontario.

Federal enforcement capacity in Ontario is limited, reactive rather than preventative, and not tailored to local ecological conditions or cumulative regional pressures. Without provincial oversight, critical nesting, spawning, staging, and migratory corridor habitats may be lost simply because they fall outside federal mandate or inspection capacity. Migratory birds and aquatic species rely on entire habitat networks, not isolated federally-regulated sites — meaning Ontario’s withdrawal from active management and enforcement effectively leaves large portions of essential habitat unprotected.

Ontario has a clear responsibility to co-govern biodiversity, not defer its obligations. Abdicating provincial protections undermines cooperative federalism, contradicts commitments under the Ontario Biodiversity Strategy, and ignores treaty and stewardship responsibilities to Indigenous Nations who have maintained deep relationships with these species since time immemorial.

Moreover, this approach is economically short-sighted. Water quality, fisheries, and migratory bird populations contribute measurable value to tourism, recreation, agriculture, and the ecological services that support healthy communities and climate resilience. Removing provincial protections risks long-term ecological degradation and economic loss that far outweigh any short-term development gains.

Ontario must maintain provincial authority and enforcement capacity for migratory birds and aquatic species to ensure robust, layered, and proactive protection that is consistent across landscapes, resilient to political cycles, and responsive to regional pressures and cumulative impacts.

5.Economic Priorities Cannot Override Biodiversity Survival
The Act explicitly embeds economic development into its purpose. While economic prosperity matters, ecosystems and species are not renewable once lost. True sustainability means no net loss of biodiversity, precautionary approach, and recovery planning based on science, not convenience.

Requested Changes:
- Restore a full ecological habitat definition
- Remove self-registration pathways for harmful activities
- Prohibit permits where critical habitat destruction is foreseeable
- Guarantee independent authority of COSSARO
- Maintain provincial enforcement for migratory birds and aquatic species
- Commit to genuine recovery and landscape-level conservation

Ontario once led Canada in species at risk protection. The SCA, as currently framed, reverses progress and puts irreplaceable species at risk. Ontario must prioritize biodiversity, climate resilience, and intergenerational stewardship, not expedited development for the sake of our future both ecologically and economically. I urge the Ministry to adopt science-based, precautionary, and recovery-oriented policy that truly protects the species and ecosystems on which all Ontarians depend.