Please consider these recommendations I feel are necessary to safeguard and advance the protection of species at risk, their habitats and the public’s right to participate in environmentally significant decisions.
Recommendations:
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Detailed habitat guidance for all listed species is ideal. Detailed guidance would be especially helpful for those species with large home ranges who are generalists - for example turtles and snakes.
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Legal Advocates for Nature’s Defence and the Friends of the Attawapiskat River jointly provide these comments (see attached) to the Ministry of the Environment, Conservation and Parks in response to the following proposals, posted to the Environmental Registry of Ontario on September 26, 2025:
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Development shouldn’t be rushed, and certainly not at the expense of the environment. Ashamed that our developers, builders and government are so uncreative they can’t imagine buildings or developments that don’t cause harm. How embarrassing for them.
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As consultants working with private landowners as they address Threatened and Endangered species concerns, we applaud the efforts to streamline the process.
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The proposed actions will harm species at risk in ontario, setting us back decades. We should be ramping up species at risk protections, not removing them to develop natural areas more easily.
Please find attached comments from Potentia Renewables Inc. to the ERO posting on "Developing guidance on section 16 activities under the Species Conservation Act, 2025"
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10 November 2025
Synthesis of full document
During our review of the proposed Species Conservation Act to replace the Endangered Species Act, we identified some potential uncertainties or ambiguities regarding the proposed SCA. Summary comments follow:
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Further to the Town’s comments regarding Bill 5 – Protect Ontario by Unleashing our Economy Act, 2025, dated May 17, 2025, prior to its enactment, Town staff remain significantly concerned about the Province’s recent and forthcoming changes to protections for species at risk.
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See Attached.
Specific details of any updates to policy and technical guidance is critical to providing regulatory certainty to industry and ensuring meaningful consultation and engagement with the impacted stakeholders.
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We welcome the invitation to provide comments on developing the new Species Conservation Act. First of all, we object to the replacement of the Endangered Species Act (ESA) with the far weaker Species Conservation Act.
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I understand the Ministry is looking for input on specific aspects of previous policies and technical direction to be retained; which components of the guidance is of greatest interest; which species
groups would most benefit from habitat guidance; and, any other advice or feedback.
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The Endangered Species Act needs to be reinstated immediately. We are risking our long term environmental well-being for short term economic gains.
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To Whom it May Concern, RE:…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170346
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The comments from the City…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170348
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For the reasons outlined in…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170450
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Please consider these…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170477
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Detailed habitat guidance…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170505
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Legal Advocates for Nature’s…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170515
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Development shouldn’t be…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170517
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As consultants working with…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170617
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The proposed actions will…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170774
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Please find attached…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170786
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Developing guidance on…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170793
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10 November 2025 Synthesis…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170804
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Further to the Town’s…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170862
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See Attached. Specific…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170863
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We welcome the invitation to…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170866
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Comments on ERO 025-0908…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170870
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Attached, please find City…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170880
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Attached is a letter from…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170932
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I understand the Ministry is…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170956
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The Endangered Species Act…
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Developing guidance on section 16 activities under the Species Conservation Act, 2025.
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170966
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