I oppose the proposal to…

Numéro du REO

025-0908

Identifiant (ID) du commentaire

170998

Commentaire fait au nom

Individual

Statut du commentaire

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Commentaire

I oppose the proposal to develop guidance on Section 16 activities under the Species Conservation Act (SCA), 2025. I call on the provincial government to repeal the SCA and take necessary steps to restore and strengthen the Endangered Species Act (ESA), committing to transparent, evidence-based conservation planning and meaningful protection for species at risk and our most vulnerable species. The guidance being proposed cannot meaningfully protect species at risk because the Act it operates under significantly weakens the foundation of species protection in Ontario.

Before any guidance can be developed, the province must restore a robust, science-based approach to defining and protecting habitat, as existed under the Endangered Species Act (ESA) prior to its replacement by the SCA.

Under the SCA, habitat is narrowly defined, recovery strategies have been eliminated, and many species may not receive mandatory protection at all due to discretionary listing processes. Without comprehensive habitat protection, it is not possible to assess risk to species survival or determine the impacts of activities on species or their ecosystems in a meaningful way.

The current proposal suggests developing guidance without the essential ecological basis needed to make that guidance effective. It is not possible to determine risk to survival if all necessary habitat (e.g., migration, feeding, reproduction, shelter) is not included in assessments. Creating guidance under an inadequate legislative framework will only mask and extend harm rather than prevent it.

Economic uncertainty cannot be used as a pretence for sacrificing Ontario's ecosystems for current and future generations. We need economic solutions that operate in collaboration with nature, not in conflict with it. Protecting biodiversity is non-negotiable not only for ecological integrity, but for cultural values, climate resilience, and the well-being of future generations across the province.