Comment
The Forest Gene Conservation Association (FGCA) provided comments on Ontario’s proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025 (ERO 025-0909). With nearly three decades of experience collaborating with industry, Indigenous communities, government, and research partners, FGCA emphasized its leadership in conserving Ontario’s forest genetic diversity and supporting the sustainable recovery of tree species.
FGCA supports modernization of conservation legislation but recommends that regulatory changes explicitly recognize the importance of genetic conservation for trees, woody plants, and forest-based vascular plants. The Association proposes that the regulations reference FGCA as a qualified organization for providing genetic expertise. It also highlights the need to consider both healthy and “lingering” individuals of species such as Butternut and Black Ash to preserve valuable genetic traits.
FGCA encourages inclusion of gene banking and tree breeding as approved conservation activities and seeks clarity on the commercial cultivation exemption, noting its nationally recognized seed certification program could ensure the use of high-quality, source-identified material. The organization also cautions that cancelling existing permits or agreements may disrupt long-term conservation contracts. FGCA reaffirms its commitment to partnering with the province to ensure the new Act effectively supports Ontario’s forest health and biodiversity for future generations.
Supporting documents
Submitted November 10, 2025 10:45 PM
Comment on
Proposed legislative and regulatory amendments to enable the Species Conservation Act, 2025
ERO number
025-0909
Comment ID
171102
Commenting on behalf of
Comment status