Thank you for the…

Thank you for the opportunity to comment on the proposed amendments connected to the Species Conservation Act, 2025. I am writing to express serious concerns about the overall direction of these proposals and the risk they pose to species at risk in Ontario.

The proposed regulatory framework does not provide the strong and science-based protections that species at risk require. The shift in authority away from independent scientific assessment and toward ministerial discretion creates a system where political and economic pressures can outweigh ecological needs. Effective conservation relies on credible, transparent science and a process that is insulated from short-term interests. These amendments weaken that foundation.

The broad exemptions proposed for industry and development create additional concern. The current language appears to allow harmful activities to proceed without adequate safeguards or clear evidence that the impacts on species and habitat will be prevented or offset. Exemptions should be narrow, justified, and accompanied by strict conditions that ensure any authorized activity meaningfully avoids harm. The proposed amendments do not meet that standard.

Habitat protection also needs stronger and more explicit direction. Species recovery is directly tied to habitat quality and continuity. Without clear definitions and firm requirements for habitat protection, recovery plans lose their effectiveness. The draft materials rely too heavily on flexible or undefined terms that leave habitat decisions vulnerable to interpretation. This increases risk for the most vulnerable species, especially those already experiencing habitat fragmentation.

I am also concerned about the limited transparency and accountability mechanisms in the proposed framework. Conservation actions should be monitored, publicly reported, and evaluated against measurable outcomes. The proposals do not clearly outline how the government will track compliance, enforce conditions, or ensure that authorized activities do not lead to further declines. Strong reporting requirements and independent oversight are essential if the Act is meant to function as a credible conservation tool.

I urge the Ministry to revise these amendments to ensure strong protections that reflect the seriousness of the biodiversity crisis in Ontario. This includes:

• Clear and science-based criteria for decisions affecting species and habitat.
• Limited and well-justified exemptions with firm protective conditions.
• Strong and enforceable habitat definitions and habitat protection standards.
• Transparent monitoring, public reporting, and independent oversight.
• Recovery planning rooted in scientific evidence and ecological integrity.

Ontario needs a regulatory framework that protects species effectively, not one that increases risk through flexibility and weakened oversight. These amendments should be revised to ensure that conservation is the central priority of the Species Conservation Act, 2025.