We welcome the invitation to…

We welcome the invitation to provide comments on developing the new Species Conservation Act (SCA), with the caveat that we strongly disagree with replacing the Endangered Species Act with the weaker Species Conservation Act. Our comments on the proposed regulations are detailed below.

1) Proposed protected species in Ontario
The current proposal suggests that all Special Concern species would be removed from the Species at Risk in Ontario List. We disagree with this approach. Species listed as Special Concern should receive protection from being harmed, harassed, or killed under the SCA.
Aquatic species and migratory bird species should not be removed from the Species at Risk in Ontario List. Although these species receive some protection on federal lands under federal legislation, this does not preclude their need for protection under provincial legislation on Crown and private lands.

2) Proposed Registration Regulation
We agree with the proposed guidance that any registered project that may affect Species at Risk “would include details such as:
• who is undertaking the activity
• what the activity is
• where and when the activity will occur
• which species may be impacted
• the extent of any species’ habitat impacted”
We also agree that information submitted to the registry should be made publicly available.
We also agree that “Additional conservation actions may be required in specific circumstances to mitigate lasting impacts. In some situations, options may be provided. These may include:
• creating, enhancing, or restoring species’ habitat
• mitigating long-term impacts to local species’ populations
• supporting key research priorities and projects”
We do not think that the current wording is strong enough. If the effects of a proposed project will have “lasting impacts”, then additional conservation actions MUST be required.

3) Proposed permit regulation
We are pleased to read that some projects will continue to need a permit to proceed. A permit should be required for any project that will likely result in the death of several individuals of threatened or endangered species, or will result in the destruction or degrading of habitat for threatened or endangered species. Furthermore, increased enforcement and oversight of permit obligations is essential and would ensure that more actions required under these authorizations are carried forward appropriately.