Vulnerable species will be…

Vulnerable species will be placed at further risk by these proposals to enable the Species Conservation Act, 2025. We are in a biodiversity crisis and the SCA is completely inadequate in managing species at risk due to the the limited definition of habitat, the discretionary listing of species, the removal of independent and science based assessment approaches, the offloading of responsibility for migratory birds and aquatic species to the federal government, the registration first approach and the elimination of recovery strategies.

Overall, the proposed regulations do not provide enough information for meaningful feedback. The lack of transparency and clarity is alarming as to how the Ministry intends to implement SCA. This prevents the ability of Ontarians from meaningfully commenting on this proposal.

I strongly disagree with proposal #3. Any activity that might impact a listed species or its habitat should undergo a permitting process with enforceable terms and conditions. There is should be significant limitations on when and how permits will be issued. If there is no enforcement, permit holders will not be held accountable.

I implore the Ministry to reconsider Proposal #4. Given that the habitat protections are weakened and the lack of recovery planning in the SCA, no exceptions should be granted for the far more limited prohibitions.