Developing guidance on…

Developing guidance on section 16 activities under the Species Conservation Act, 2025:
1. Draft guidance documents should be made available for public review prior to finalization. Providing proponents and implementers with an opportunity to review and comment will help identify potential challenges and reduce the likelihood of unforeseen implementation issues.
2. Specific technical guidance should be developed for habitats associated with bat species at risk as these species are commonly encountered on projects in southern Ontario. Specific guidance should address the treatment of isolated trees and buildings requiring demolition.
3. Furthermore, technical guidance should include the definition of “damage” to habitat to ensure uniform interpretation and application across all projects.
4. Inclusion of specific guidance on mitigation measures and alternative approaches would be beneficial as timing windows for construction may not always be feasible.

Proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025:
Several key details require clarification to ensure effective and consistent implementation to balance objectives and streamline approvals.
• There are details that are lacking, including what the registration exemptions will require of proponents and how the fees for registration will be calculated. We would like an opportunity to review the regulations prior to enactment.
• Providing proponents and those responsible for implementing the regulatory framework an opportunity to review will help identify and address concerns before they arise.
• The province should clarify how Conservation Actions will be identified, evaluated and approved. It is our understanding that this may include habitat restoration, mitigation, and/or support for key research priorities. Clear criteria or “tests” should be established, to the extent they may apply.
• Similar to MyOntario accounts, we recommend that the new registration system include the ability for proponents to designate a qualified representative to assist with completing and managing registrations.