As a not-for-profit…

As a not-for-profit organization with 28 years of experience and success in species recovery, particularly with high-profile tree species at risk (SAR), the Forest Gene Conservation Association feels compelled to express both our concerns and our recommendations.

-Tree SAR requires more than intact root zones—they need access to neighboring populations for gene flow and viable reproduction.
-A "registration first" model that permits habitat disturbance without advanced notification or scientific vetting will compromise our critical gene conservation work, especially where potentially tolerant, resistant or
lingering individuals (post insect infestation) are concerned.
-The proposed changes put jobs and specialized skill sets and the ecological outcomes they support for current and future SAR- at risk.
-Voluntary initiatives cannot replace robust, science-driven conservation.
-The Ministry must expedite the spending of Conservation Funds to implement critical provincial conservation efforts. We cannot afford any more delays, including the slow development of a program. Mobilizing the funding acquired to date must be prioritized.

To enhance the logistical and cost effectiveness, fairness, and scientific integrity, we recommend:
-Ensuring that registration processes do not prevent ex-situ conservation and gene banking of tolerant individuals.
-If critical habitat for tree SAR will no longer be protected, it is imperative that DNA be collected through ex-situ gene conservation activities to conserve and improve the genetic diversity of the species where habitat does exist. This is the case if there will no longer be adjacent trees,
pollinator access, and breeding areas for gene flow to resume.
-Those responsible for enforcement for tree species at risk should have significant training in tree biology and be required to maintain competence on forest genetics.

To ensure logistical and cost effectiveness, under the Species Conservation Program, the FGCA recommends:
-Establishing a vetting process to ensure funding goes to organizations with demonstrated success and credibility in species conservation and recovery, which are long-term challenges.
-Maintaining the requirement for preparation and implementation of recovery strategies and progress reviews to monitor conservation effectiveness.
-Reducing long funding turnaround times- which delay and undermine recovery capacity and increase costs. Waiting 3-6 months for funding approval will impact delivery timelines.
- Retaining and establishing advisory committees consisting of credible organizations like the FGCA to ensure technical expertise informs decision-making.
-Develop a funding program that takes a holistic approach for long-term and strategic funding instead of a solely project by project approach, this will lead to greater external investment, cost and operational efficiencies.

The Forest Gene Conservation Association remains firmly opposed to the proposed changes to the Endangered Species Act as outlined in ERO #025-0380. We believe that these changes, if implemented as proposed, will significantly weaken protections for Ontario’s species at risk, particularly tree species, by prioritizing administrative expediency over ecological science, recovery planning, and long-term resilience.

That said, our longstanding and successful track record of collaboration with the Province, especially on the conservation and recovery of tree species at risk, demonstrates our commitment to solutions that are both scientifically grounded, economically efficient and operationally practical. We are ready and willing to inform, guide, and deliver on tree and plant species conservation and recovery efforts.

FGCA stands ready to work with the Ministry of the Environment, Conservation and Parks to ensure that Ontario’s forest genetic resources are not only protected, but restored in a way that supports biodiversity, climate resilience, and community engagement. We urge the Ministry to reconsider its approach, re-engage with the scientific and conservation communities, and invest in those with the demonstrated experience to aid in conservation efforts and deliver results.