First off, I'd like to tell…

First off, I'd like to tell you this is not the place to for self-congratulatory messages about how supposedly good you are for the economy and how good you are at fighting Trump's tariffs. This is the Environmental Registry, not the PC party website.

I want to say that it is important that special concern species continue to be listed at https://www.ontario.ca/page/species-risk and have their own webpages under the ontario.ca domain especially since they will no longer be included in regulations.

I also think that you cannot remove the protections because despite the contents of this notice, the 42 aquatic and bird species may not be protected by the Species at Risk Act, Fisheries Act, or the Migratory Birds Convention Act, 1994, as those acts are listed in Schedule 2 of the Building Canada Act, which means the Governor in Council can provide they do not apply, even if it means eradicating a species.

Based on the information provided, many activities which currently require a permit, for which public consultation on this public registry is required before they can be issued, will now take place on a new registry which information submitted to may not even be made public. I strongly disagree with this approach. The government was not clear in its proposal enacting the Species Conservation Act (025-0380) that Ontarians would be losing access to their consultation and information rights. I disagree with separating out species at risk matters into a new registry, but if you proceed despite this, at least publish notices here linking to new postings on this new registry. This new registry should fully respect Ontarians existing consultation and information rights and act in accordance with the principals and purposes of the Environmental Bill of Rights. This means that if you decide to move forward this registry, consultation with the public for a minimum of 30 days, but longer if 30 days is not appropriate, before a decision is made to approve a registration, amend a registration based on the feedback, or deny a registration.

The proposal mentions a list of activities requiring so-called specific requirements, but does not say what these requirements would or could be. It is hard to comment on undescribed requirements. It also mentions that specific circumstances, which are undefined that require additional conservation actions. This offers more insight into what is not currently being considered as a general rule for registered activities. I am worried that activities that harm a species a habitat will not generally come with the requirement of doing anything to offset this loss, just in what you consider to be "specific circumstances". I am also worried that long-term mitigation efforts are also only being considered in specific circumstances. So, is it generally okay if an activity wipes out half of an endangered species over several years instead of several weeks? I also have concerns about the common conservation requirements for registrations. Who will these experts be? Will they be public servants in the Ministry, people certified by the government, people who have a specific type or types of degrees, diplomas and/or certificates? Will the Ministry ensure they are independent from registrant or proposed registrant? Will they be required for all registrations? The use of the word may is confusing. Also, if a person doesn't comply with their conversation requirements, can their registration be suspended or revoked? Review of the materials and proposal leaves this unclear. Why is a registration not automatically void if the registrant is non-compliant with the conditions? The protections offered in this proposal for registrations are too weak and vague to provide meaningful protection to species at risk.

I really think the government should require permits for more activities. I disagree that any activities that require a permit under the Endangered Species Act, should only require a registration. However, I cannot believe you didn't include destroying endangered species habitat as permit activity. Why do you want to make it easier to harm endangered species, capture endangered species, damage endangered species habitat, destroy endangered species habitat, sell captured endangered species, and lease captured endangered species? This will not make Ontario or our environment better.

As for exceptions, are you proposing to extend the exception set out section 4.1 of O. Reg. 242/08. That section is currently set to be revoked December 31, 2025. If you are, I'd like to see the reason for this change.

As for designation of the Act under the Environmental Bill of Rights, it should be designated under Part II. The current Endangered Species Act is designated under Part II. Ontarians should not see their participation rights reduced as a result of this proposal. The government should be required to consult with the public before removing a species from the Protected Species in Ontario List, changing an activity from a permit activity to a registration activity, changes to grounds for suspension or revocation of a registration, changing to information required to be given to the Ministry by a person, changes to restrictions on registration, granting a new exception to the Act, or limiting the habitat protections, or granting a permit to kill endangered species, for example.

Overall, I do not think the government should move forward with implementing the Species Conservation Act, 2025. I think the government should repeal this act.