June 30, 2025
Introduction:
The Ontario Human Rights Commission (OHRC) welcomes the opportunity to offer this submission on Bill 33’s proposed amendments to the Education Act, which would require school boards to work with local police services to implement School Resource Officer (SRO) programs where available.
To uphold the dignity, self-worth, and safety of students, the OHRC urges an evidence-based approach to the routine presence of police in Ontario’s schools. Currently, there is a lack of evidence supporting the effectiveness of SRO programs. The OHRC recommends a provincial review of such programs before adopting a legislative framework. Such review should also consider the value of investments in student well-being as a means to enhance safety.
The Education Act must be developed, interpreted, and applied in a manner consistent with the Ontario Human Rights Code. That Act should avoid reinforcing, perpetuating, or worsening the disadvantages faced by Indigenous, Black and 2SLGBTQ+ students, and students with disabilities. Promoting supportive education environments through a human rights-based approach is essential for developing effective school safety policies.
Background of the OHRC
The OHRC is a statutory human rights body established under the Ontario Human Rights Code (Code). Its primary role is to promote and advance human rights, while addressing systemic discrimination in Ontario. The OHRC achieves this by developing policies, conducting public inquiries, and engaging in strategic litigation.
For decades, a key focus of the OHRC has been advancing the rights and interests of students, particularly those who are historically marginalized. The Commission works to identify and eliminate systemic barriers within the education system. To support these efforts, the OHRC has created resources and published reports to help identify, monitor, and reduce discrimination in the education system. Notable among these are the Right to Read,[1]the OHRC’s public inquiry report addressing human rights issues faced by students with reading disabilities in Ontario’s public education system, and Dreams Delayed: Addressing systemic Anti-Black Racism and Discrimination in Ontario’s Public Education System (Dreams Delayed),[2]an action plan to address anti-Black racism and discrimination.
As part of its initiatives supporting Dreams Delayed, the OHRC released a Compendium of Recommendations drawn from previous reports which address systemic racial discrimination in education. A central tenet of Dreams Delayed is the recognition that student well-being is foundational to a successful education system, and that discriminatory practices hinder students’ interests, capacities, and aspirations.
The OHRC’s work in Ontario’s education system finds that protection from discrimination under the Code is often not experienced by students, particularly those from Black and other racialized communities, 2SLGBTQ+ communities, or students living with disabilities.
The OHRC has also undertaken significant work to address systemic racial discrimination in policing. It has developed resources to help police services identify, monitor, and reduce discrimination. These include Paying the Price (2003), the OHRC’s inquiry report into the effects of racial profiling; Under Suspicion (2017), a research and consultation report on racial profiling; and the Policy on eliminating racial profiling in law enforcement (2019), developed in collaboration with the Ontario Association of Police Chiefs (OACP). As well, the OHRC has collaborated with Peel Regional Police under a Memorandum of Understanding to address systemic racism and discrimination.
In addition, the OHRC has submitted numerous recommendations to government and independent reviewers on how to address systemic discrimination in policing. The OHRC’s 2021 Framework for change to address systemic racism in policing (Framework for Change), identifies 10 essential steps for addressing discriminatory practices in policing throughout the province. In 2023, the OHRC released From Impact to Action, the final report from its inquiry into anti-Black racism within the Toronto Police Service. That report contains over 100 recommendations to address systemic anti-Black racism, including seventeen specific recommendations directed to the province.
OHRC’s work on Police in Schools
In 2017 the OHRC released Under Suspicion, a research report on racial profiling in Ontario. The report included a discussion on racial profiling in the education system by police officers. The report cites concerns about police being allowed into schools on a “regular basis” and finds that officers in schools may over-scrutinize or inappropriately question students.[3] Under Suspicion also emphasizes that racial profiling in schools can have serious long-term negative effects on students and has been linked to school disengagement, poor academic performance, and involvement in the criminal justice system.[4]
In July 2021, the OHRC released the Framework for Change, which recommended a province-wide review of SRO programs. Based on research findings from various school boards in Ontario, the Framework states that “racialized students are more likely to be disciplined, suspended and arrested in school when police are present, and do not think police presence contributes to their sense of safety and security.” The Framework also notes that there has been a shift towards ending SRO programs in response to concerns raised by racialized communities and other historically disadvantaged groups.
In December 2022, the OHRC sent a letter to the Toronto District School Board (TDSB), in response to a special meeting on school and community safety. At the time, at least one Trustee called for the return of the SRO program which was cancelled in 2017. The OHRC reminded the TDSB of research regarding racialized students and their negative experiences with SRO programs; and encouraged the board to incorporate human rights principles when drafting future reports or recommendations on this issue. In April 2022, the OHRC wrote a similar letter to the York Catholic District School Board in response to a review of its SRO program.
As a party to the Human Rights Project in Peel, the OHRC has made recommendations to the Peel Regional Police and the Peel Regional Police Services Board to address systemic racism and discrimination. As part of this work, the OHRC examined the role and impact of School Resource Officers and attended consultations in Peel regarding this issue. In response to concerns raised by Black students, parents/guardians, and educators, the OHRC supported community calls to end the SRO Program in Peel.[5]
Black communities also shared their experiences with SRO programs during community consultations for the Dreams Delayed report. Community members urged the OHRC to continue its work to combat systemic racial discrimination and the harms associated with police-in-schools programs. With respect to this issue, the report concludes that:
Any decision regarding police involvement in schools should be made only after carefully considering existing research and in consultation with all local voices, including parents, students, community members and organizations. School boards have a responsibility to ensure that the Code-protected interests of all students are acknowledged and protected when developing strategies to address safety concerns. Boards should follow the OHRC’s Human Rights-Based Approach Framework to ensure that any policies prioritize human rights.[6]
Concerns Regarding Bill 33
By mandating the implementation of SRO programs, Bill 33 disempowers school boards and prevents them from fulfilling their responsibilities to protect the rights of all students under the Ontario Human Rights Code. This is particularly concerning in jurisdictions, including Peel and Toronto, where Black students and communities have routinely communicated the systemic harms associated with SRO programs.
Bill 33 shifts decision-making authority to law enforcement by proposing regulations that may prescribe the “...circumstances in which school boards shall provide local police services with access to school premises” or “permit” their participation in school programs. If enacted in its current form, Bill 33 would override established local police-school protocols, disrupting relationships that have been shaped by community-specific needs and grounded in dialogue between school boards, police services, and ministries. Currently, these protocols reflect the policy direction from the Ministry of Education and the Ministry of the Solicitor General (formerly the Ministry of Community Safety and Correctional Services). The protocols promote dialogue and provide its signatories with the opportunity to address the unique factors that may affect local service-delivery arrangements.[7]
This model allowed education service providers and schools to shape community-police involvement at the local level. In the absence of a provincial mandate, school boards and police services have been able to adapt their engagement in response to community-based needs. For example, in 2020, following extensive consultation with affected communities, Peel Regional Police (PRP) ended their SRO program. In a public statement, PRP acknowledged that segments of the community expressed “…long-standing concerns about systemic racism and the disproportionately punitive effects this type of traditional programming can produce.”[8] The Peel District School Board (PDSB) supported this decision, stating: “We have heard from members of our school communities, in particular those who identify as Black and Indigenous, that they do not feel safe when SROs and other police officers are present in Peel schools.” [9] In 2021, PDSB and other local school boards worked with PRP to develop a protocol that aims to “promote the wellbeing of students”. This Protocol expressly states that officers will not be dispatched to schools when there is “no criminality or breach of other statutes and there is no known imminent threat to public safety or to the school environment.”[10] The Protocol adopts a human rights and trauma informed approach and identifies these principles as key elements of the safety strategy.[11]
The OHRC is also concerned that Bill 33 does not define what constitutes SRO programming. SRO programs are typically described as strategies that routinely station a police officer within a school. They have existed in both elementary and high schools. In some cases, police officers are assigned to one school; in others, several schools share the same SRO officer. Their programming may include issues unrelated to policing or law enforcement. Because Bill 33 puts the onus on schools to implement SRO programs “where such programs are available”, police services will have the authority to design and implement a wide range of initiatives without consulting educators. School boards and educators are best positioned to design programs for students. Moreover, the Bill is unclear about whether schools or school boards will be expected to subsidize the presence of SROs in schools, and if so, in what way.
In addition, the Bill does not distinguish between the use of SROs in elementary and high schools, despite the clearly different needs and circumstances of younger students. School boards that have paused or ended their SRO programs in response to community-based concerns about systemic discrimination will be faced with the unworkable task of re-instating these programs, despite their known harms, while continuing efforts to build and create educational spaces that foster the development of all students equally and without discrimination.
School boards must retain the ability to develop policies that protect students and provide feedback to decision-makers. Without this, Bill 33 presents a substantial risk to the learning environment and climate in Ontario schools.
Research findings on SRO programs in Ontario
In response to longstanding concerns from historically disadvantaged groups, several school boards in Ontario have critically assessed the viability of their police in school programs. For example, in 2021, the Ottawa Carlton District School Board’s (OCDSB) Office of Human Rights and Equity Advisor conducted a review of its SRO program and all legally discretionary activities of officers. The review made important findings about the experience of students from a range of historically disadvantaged groups, including racialized students, students with disabilities and students from 2SLGBTQ+ communities.
The review found that students from marginalized groups may experience the presence of police in schools more negatively. Survey research conducted for the review found that 62% of Black, 33% of Middle Eastern, 36% of Muslim, 48% of people with disabilities, and 68% of 2SLGBTQ+ respondents disagreed with the notion that police presence makes schools a safer place.[12]
The review included recommendations to revise the OCDSB’s policies and procedures in a manner that will “… limit police involvement in schools to responding to issues that require mandatory notification of the police unless it is a last resort.”[13] Following the review, the OCDSB ended its SRO program and apologized to the students and communities that were harmed by the program.[14]
Similarly, in 2017, the Toronto District School Board ended their police in school program after conducting a comprehensive review. Qualitative findings from student focus groups found that most students were “very uncomfortable” with having an SRO placed in their school and felt intimidated by the presence of an officer. This experience caused some students to stay away from school.[15] Despite measurable support for continuing the SRO program, the review committee concluded that, “our priority must be to mitigate against the differentiated and potentially discriminatory impact of the SRO program as described to us by some of our students and communities.”[16] After considering the findings and recommendations from the review, the TDSB ended its SRO program.[17]
Impact on Indigenous Communities
The historical relationship between Indigenous Peoples and police has included numerous examples of dispossession by the state of their lands and children. This includes forcibly removing Indigenous children from their homes to place them in non-Indigenous adoptive homes and forced relocation to Residential Schools.[18]
Subsequently, the relationship has been characterised by both over-policing and under-policing. As asserted nearly thirty years ago by the Royal Commission on Aboriginal Peoples, Bridging the Divide: A Report on Aboriginal people and Criminal Justice in Canada: “...Aboriginal communities received proportionately greater law enforcement attention and proportionately less peace-keeping and other services.”[19]This history contributes to negative outcomes including the overrepresentation of Indigenous youth in correctional facilities as, “more than four in ten (43%) of youth admissions to correctional services in 2018/2019 were Indigenous, despite accounting for 8.8% of the total youth population.”[20]
SRO programs exist within this broader context of state-sanctioned harm and systemic distrust. The OHRC submits that intervention and responses to safety concerns should be trauma-informed, community-based, wholistic, and culturally relevant.[21] In short, efforts to promote school safety should not be at the expense of Indigenous youth.
Gaps in research regarding the effectiveness of SRO Programs
There is a lack of evidence supporting the effectiveness of SRO programs and a lack of evidence showing that such programs have a positive impact on student safety or create a positive perception of the police. Instead, research indicates that SRO programs do not lower crime rates.[22] An examination of police data from Victoria, British Columbia (B.C.) by the B.C. Human Rights Commission found no correlation between increased gang activity and the cancellation of SRO programs.[23] In Toronto, a study found that one year after an SRO program had been in place at a school, reports of crime on school grounds had decreased, while reports of crime in the 200-meter vicinity of the school increased, suggesting SROs only moved crime slightly off campus.[24]
The Ontario Association of Chiefs of Police have also acknowledged there is not enough data or research on the efficacy of SRO programs. In a statement on SROs, the OACP noted, “Police leaders need more and better research that not only evaluates SRO programming, but one that also pays close attention to the needs and experiences of Black, Indigenous and People of Colour (BIPOC) students.”[2] They further emphasized that, “It is time for police leaders to support evidence-based SRO research, particularly with respect to evaluation that places the experiences of BIPOC students front-and-centre.”[26]
In short, there are significant gaps in the evidence supporting SROs. There is a need for research in the Canadian context that centers the experience of marginalized students. Given the documented negative experiences that have been reported by marginalized students and groups, Ontario has an obligation to fill this evidentiary gap before mandating such programs on students and schools.[27]
Alternatives to SRO programs
Building positive relationships between police and students can be accomplished through methods other than SRO programs. By using a trauma-informed approach – where activities with police are optional, require consent, and are thoroughly communicated – students and parents can be empowered to make choices to engage with the police.[28]
After ending their SRO programs, some school boards and police services developed ways for students and staff to interact with police in a voluntary and trauma informed manner. Some have moved opportunities to engage with police off campus.
In Collingwood, for example, a former SRO has weekly availability during lunch-time hours at a nearby chapel, off school property for students to engage, if they choose.[29] Similarly, the Ottawa Police Service assigned a dedicated officer to each school district to support educators without officers being stationed in the school, allowing educators to access support as needed while maintaining a student-centered, non-intrusive model.[30]
These alternatives demonstrate that student-police engagement does not require constant on-site police presence. Instead, flexible, transparent, and student-informed models can promote safety while respecting the dignity, autonomy, and well-being of all students, particularly those from historically marginalized communities.
Recommendations from prior reports
As part of the OHRC’s Anti-Black Racism and Discrimination in Education initiative, the OHRC conducted a comprehensive review of past reports that address anti-Black racism and discrimination in education. This review resulted in a “Compendium of Recommendations,”[31] reflecting recommendations advanced by experts, researchers and community members to address systemic barriers facing Black students. Police-in-school programs were consistently identified as an area of concern, and several recommendations were made to improve outcomes. These recommendations included increasing funding for social supports to address the root causes of inappropriate behavior and placing clear limits on the types of incidents that require police involvement in schools.
Before proceeding with Bill 33 or making further amendments to the Education Act, the OHRC strongly encourages Ontario to review the Dreams Delayed report and the Compendium of Recommendations.
The OHRC’s recommendations:
The Education Act recognizes the importance of safeguarding rights under both the Code and the Canadian Charter of Rights and Freedoms (the Charter). To ensure that these rights are protected, the OHRC recommends the following:
- Amendments to the Education Act must be evidence-based: The amendments to the Education Act must be evidence-based and promote human rights. The empirical evidence available to date does not confirm that student safety and well-being are improved by SRO programs, and there is evidence of significant harm. To effectively protect student safety, dignity and self-worth Ontario must work to address this gap in the evidence before it considers legislation that mandates SRO programs province-wide.
Provincial Review of SRO Programs: The OHRC calls for a provincial review of SRO programs. The OHRC initially called for this review in 2021 in its Framework for Change to address systemic discrimination in policing. The review should examine the impact of SRO programs on students and must be centred on the lived and living experiences of Black, Indigenous, and 2SLGBTQ+ students, who are the most disproportionately affected.
In response to gaps in research and evidence about Canadian SRO programs, British Columbia’s Human Rights Commissioner called on B.C.’s provincial government to fund a provincial study of SROs that centres the perspectives of marginalized students and employs evaluation strategies that lead to independent, credible, definitive, and externally valid findings.[32] Ontario should incorporate this approach in its review.
- Invest in student well-being: Improving student safety can be accomplished by increasing social supports and in-class and in-school strategies to promote attachment to education and the school community for all children and youth. Community voices, including those heard during the OHRC’s consultations on anti-Black racism and discrimination in education have identified a pressing need for more social supports in schools; not more policing. Communities requested increased levels of peer support, educational assistants, hall monitors, counsellors and mental health workers. The OHRC heard repeated calls for wrap-around supports that include housing, food security and childcare to help vulnerable children, schools, and communities.
Systemic discrimination in policing and the education system is a threat to the well-being of all children in the education system. To foster student well-being and achievement, the dignity and self-worth of each student must be protected, and systemic barriers must be collapsed. For many young pupils, the mandatory and routine placement of an officer at their school undermines their safety and disrupts their sense of belonging. Given this reality, legislation should not prevent duty holders in the educational system and policing from working with students and the community to develop non-discriminatory safety strategies.
School boards and police services that have listened to communities, paused their SRO programs, and re-designed their engagement strategies in accordance with human rights principles should be encouraged. This approach provides a positive path forward for duty-holders and students who have a right to enjoy learning spaces that are free from discrimination and violence.
[1] Ontario Human Rights Commission, Right to Read: Public inquiry into human rights issues affecting students with reading disabilities (2022), Online: https://www.ohrc.on.ca/en/right-read-inquiry-report-0
[2] Ontario Human Rights Commission, Dreams Delayed: Addressing systemic Anti-Black Racism and Discrimination in Ontario’s Public Education System (Dreams Delayed) (2025), Online: https://www3.ohrc.on.ca/en/dreams-delayed-addressing-systemic-anti-black-racism-and-discrimination-ontarios-public-education#ExecutiveSummary
[3]Ontario Human Rights Commission, Under Suspicion: Research and Consultation Report on Racial Profiling in Ontario (2017), Online: https://www3.ohrc.on.ca/en/under-suspicion-research-and-consultation-report-racial-profiling-ontario
[4]Ibid at page 62; Also see Racial profiling in schools can have serious long-term negative effects on students.
[5]Human Rights project. Recommendation 12(p) states: “The Police School Response Program should be terminated effective immediately allowing the school boards to establish appropriate protocols. See: Peel Regional Police, Work plan to eliminate racial profiling and racial discrimination between the Peel Regional Police, Peel Police Services Board and the Ontario Human Rights Commission (June, 2023), Online (pdf): https://www.peelpolice.ca/en/who-we-are/resources/Documents/OHRP/OHRC-Recommendations-22-June-2023v2-accessible.pdf
[6] Ontario Human Rights Commission, Dreams Delayed Addressing Systemic Anti-Black Racism and Discrimination in Ontario’s Public Education System (2025), Online: https://www3.ohrc.on.ca/en/dreams-delayed-addressing-systemic-anti-black-racism-and-discrimination-ontarios-public-education
[7] Ontario, Provincial Model for Local Police-School Protocol. Online (pdf): https://files.ontario.ca/edu-provincial-model-local-police-school-board-protocol-en-2021-11-02.pdf
[8]Peel Regional Police, Update: the Dissolution of the School Resource Officer (SRO) Program, (18 November, 2020) Online: https://www.peelpolice.ca/modules/news/index.aspx?newsId=270c81ed-37eb-43df-93e9-b7d6ad47f1bf
[9] Peel District School Board, Peel Regional Police Pauses School Resource Officer Program, (28 July, 2020), Online: https://www.peelschools.org/news/Peel-Regional-Police-pauses-School-Resource-Officer-program2022-06-29-18:45:45.503752+00
[10] Peel Regional Police, Peel District School Board et al., Local Police School Protocol 2021 at page 12 Online (pdf): https://www.peelschools.org/documents/79119436-6e62-465f-be74-7d3e0acde930/Police_and_School_Board_Protocol.pdf
[11]Ibid at page 6.
[12]Carolyn Tanner, “Policy and Practice Review of Police Involvement in Schools”, Ottawa-Carleton District School Board, (June 2021) at page 46, Online (pdf): https://www.ocdsb.ca/download/481531
[13]Ibid at Appendix 15 page 145.
[14]Ottawa-Carlton District School Board, We Apologize (10 June, 2021), Online: https://www.ocdsb.ca/news/we_apologize
[15] Toronto District School Board Planning and Priorities Committee, School Resource Officer Program Review, (15 November , 2027, at page 3 Online (pdf): https://briarpatchmagazine.com/pdf/TDSB_School_Resource_Officer_Program_Review.pdf
[16]Ibid.
[17] Ibid at page 5.
[18] Marcel-Eugène LeBeuf, The Role of the Royal Canadian Mounted Police During the Indian Residential School System (2011), Online (pdf): https://nctr.ca/wp-content/uploads/2021/01/RCMP-role-in-residential-school-system-Oct-4-2011.pdf Royal Canadian Mounted Police Path of Reconciliation: Strengthening Trust in the RCMP (2020), Online: https://www.rcmp-grc.gc.ca/en/reports-research-and-publications/rcmp-path-reconciliation-strengthening-trust-the-rcmp?wbdisable=true
[19] Cited in: Allan S. Manson et al, Sentencing and Penal Policy in Canada: Cases, Materials and Commentary, 4th Ed. (Toronto: Emond, 2024) at page 743.
[20] Jamil Malakieh, “Adult and youth correctional statistics in Canada, 2017/2018.” Juristat. Statistics Canada Catalogue no. 85-002-X (2019).
[21] Ontario Federation of Indigenous Friendship Centres, “Trauma Informed Schools “Ask me about trauma and I will show you how we are trauma-informed”: A Study on the Shift Toward Trauma-Informed Practices in Schools” OFIFC Research Series Volume 4 (2016), Online (pdf): https://ofifc.org/wp-content/uploads/2020/03/Trauma-Informed-Schools-Report-2016.pdf
[22]Dr. Kanika Samuels-Wortley, “ The state of school liaison programs in Canada” Office of the B.C. Human Rights Commissioner, (May, 2021) at pages 9-10, 18-19, Online (pdf):https://bchumanrights.ca/wp-content/uploads/Samuels-Wortley_May2021_School-liaison-programs.pdf , Aaron Kupchik, “Research on the Impact of School Policing” in Police and Pennsylvania’s Schools: What Education Leaders Need To Know (ACLU Pennsylvania, October, 2019) at page 8, Online (pdf): https://www.aclupa.org/sites/default/files/field_documents/police_and_pennsylvania_schools_report_digital_10.14.2019.pdf
[23] Kasari Govender, Commissioner of the B.C.’s Office of the Human Rights Commission (3 February, 2025), Online (pdf): https://bchumanrights.ca/wp-content/uploads/BCOHRC_Feb2025_Letter-to-Beare-Begg-re-SPLOs.pdf
[24] Dr. Kanika Samuels-Wortley, “The state of school liaison programs in Canada” Office of the B.C. Human Rights Commissioner, (May, 2021) at page 18, Online (pdf): https://bchumanrights.ca/wp-content/uploads/Samuels-Wortley_May2021_School-liaison-programs.pdf
[25]Ontario Association of Chiefs of Police, Statement: School Resource Officer Programs, (20 July, 2020) Online: https://www.oacp.ca/en/news/statement-school-resource-officer-programs.aspx
[26]Ibid.
[27] Kasari Govender, Commissioner of the B.C.’s Office of the Human Rights Commission (3 February, 2025), Online (pdf): https://bchumanrights.ca/wp-content/uploads/BCOHRC_Feb2025_Letter-to-Beare-Begg-re-SPLOs.pdf.
[28]Joshua Santos, “'Asking for some trust': Police, boards agree officers may return to York Region schools” Newmarket Today (19 September, 2024) Online: https://www.newmarkettoday.ca/police-beat/asking-for-some-trust-police-boards-agree-officers-may-return-to-york-region-schools-9545456; Centre for Organizational Effectiveness, “SRO Program Review Elgin, London, Middlesex, Oxford Phase III – Progress Update” (November, 2023) at page 4, Online (pdf): https://22.files.edl.io/cfca/09/28/21/183020-1d0e8150-e7c5-48e8-84d8-2a0360279657.pdf; Peel Local Police and School Protocol, (2021), Online (pdf): https://www.peelschools.org/documents/79119436-6e62-465f-be74-7d3e0acde…; . Logical Outcomes, “Review of police presence and programs at the GECDSB” (9 January, 2023) at page 45, Online(pdf): https://www.publicboard.ca/en/about-gecdsb/Plans-and-Reports/GECDSB_Review_PolicePresencePrograms_Final-AODA-R1.pdf.
[29]Jessica Owen, “Collingwood pushes boards to re-instate police in schools” Collingwood Today (24 February, 2024), Online: https://www.collingwoodtoday.ca/local-news/collingwood-pushes-boards-to-re-instate-police-in-schools-8343321.
[30] David Fraser, “Ottawa police assign youth officers to city's school districts” CBC News (30 January, 2025) Online: https://www.cbc.ca/news/canada/ottawa/ottawa-police-assign-youth-officers-to-city-s-school-districts-1.7445112
[31]Ontario Human Rights Commission, Anti-Black Racism in Education: Compendium of Recommendations, Online: https://www3.ohrc.on.ca/en/anti-black-racism-education-compendium-recommendations
[32] Kasari Govender, Commissioner of the B.C.’s Office of the Human Rights Commission (3 February, 2025), Online (pdf): https://bchumanrights.ca/wp-content/uploads/BCOHRC_Feb2025_Letter-to-Beare-Begg-re-SPLOs.pdf