I am concerned about the…

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025-0380

Comment ID

126318

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I am concerned about the proposed changes under Bill 5 Protect Ontario by Unleashing Our Economy Act, 2025. Specifically, I am deeply concerned that the proposed repeal of the Endangered Species Act, 2007 (ESA) and its replacement with the Species Conservation Act, 2025 (SCA) will significantly weaken protections for vulnerable species and their habitats.

Firstly, a registration-first approach shifts the responsibility entirely to the proponent, and removes important oversight that is necessary for responsible development. A permitting system that includes oversight is necessary, as it holds industry accountable for avoiding and protecting key habitats for our species at risk in Ontario.

Giving the government discretion to decide which COSSARO-assessed species receive protection, and which don’t, removes objectivity from what should remain a science-based process.

Though I agree that the current definition of habitat for some species lacks clarity, narrowing the definition only allows for the exclusion of habitats that are crucial for the survivability of our species at risk. Instead, the government should put resources into developing species-specific definitions of habitats, rooted in science, to meet the goals of both protecting sensitive habitats, and allowing for development of crucial infrastructure for Ontarians.

Further to this, removing the requirement for the development of a recovery strategy and having no means by which to evaluate the success of a species recovery overtime reduces accountability, and undermines the act itself by providing no path forward for the conservation of the species. This is a huge step backwards. Instead, the provincial government should focus on filling knowledge gaps through investments into research that provides data to support the development of protocols for the detection of species, determination of critical habitat, and identifying opportunities for beneficial actions for species. This once again works towards the protection of the most sensitive habitats for species, and allows room for growth.

Management of natural resources, and therefore species at risk habitat, falls under the provinces mandates. It is imperative to continue to develop localized strategies, taking into consideration Ontario's unique landscapes. In addition, removing the function of formal advisory committees leaves a gap, and further limits the provinces ability to collaborate with organizations in promoting conservation efforts.

I strongly support the need for the government to maintain automatic legal protection for all species classified by COSSARO as extirpated, endangered, or threatened, to ensure decisions remain grounded in science. Permit-based oversight should be retained for activities that pose moderate to high risks to species or their habitats, rather than relying solely on a registration system. The proposed definition of habitat should be expanded to reflect the full ecological needs of species, including foraging, dispersal, and seasonal use areas. I also urge the government to preserve a legislated recovery planning process to provide a clear, coordinated path for species recovery. Finally, dedicated and transparent funding should be sustained, along with mechanisms for expert and stakeholder input, to support meaningful, collaborative conservation outcomes.

Streamlining the system should not mean weakening species protection. I urge the government to ensure that any new legislation remains grounded in science, transparency, and a strong commitment to Ontario’s biodiversity.