Public Input Coordinator…

Public Input Coordinator
Species at Risk Protection, Species at Risk Branch

Alderville First Nation would like to share its concerns regarding the Ford government’s proposed changes to the Ontario Endangered Species Act, currently titled the Protect Ontario by Unleashing Our Economy Act, 2025.

The proposed amendments are significant and will have substantial impacts on Species at Risk (SAR) in Ontario. These changes would weaken the foundational protections currently provided under the Ontario Endangered Species Act—protections that have been carefully developed over years of evidence-based planning and implementation.

Further, the proposed replacement of the Species at Risk Stewardship Program with a new Species Conservation Program raises concerns about disruption and due process in the continuity of SAR protection efforts—specifically, the displacement of staff with expertise in administering the Act.

To summarize, we believe the proposed legislation will:
• Shift species-related authorizations to a registration-based model, removing the need for permits or Ministry review of activities affecting SAR or their habitats. Proponents would self-register and proceed under as-yet-undefined “conditions.”
• Remove “harass” from Section 9 prohibitions, narrowing the definition of harm to only physical impacts such as killing or injury, potentially leaving other key disturbances to SAR unaddressed.
• Revise the definition of “General Habitat” to exclude areas critical to species survival, such as migration routes, breeding areas, and foraging grounds.
• Eliminate legislated requirements for recovery strategies and related government response statements, along with progress reporting by proponents—components central to SAR recovery.

Finally, the introduction of a new Protected Species in Ontario List would replace the current Species at Risk in Ontario (SARO) list. This would give the provincial government authority to add or remove species from protections without independent oversight. This action would fundamentally erode transparency and accountability in the listing process and undermine the intent of provincial SAR protections.

Alderville First Nation is a recognized rights holder under Treaty law, affirmed under Section 35 of the Constitution Act, 1982. As such, Alderville First Nation's rights must be meaningfully upheld in any legislative process. Proposed revisions to the Ontario Endangered Species Act must not infringe upon these rights without rigorous consultation and accommodation. Attempts to diminish protections for Species at Risk without the full engagement of Alderville First Nation and Williams Treaties First Nations would constitute a breach of the Crown’s duty to consult.

Sincerely,
Alderville First Nation Chief and Council