I am writing to express my…

I am writing to express my strong opposition to Schedule 6 of Bill 5, the proposed Species Conservation Act, 2025, which repeals the current Endangered Species Act, 2007. I believe the changes outlined in this bill will significantly harm Ontario’s environment and weaken critical protections for species at risk.
My key concerns include:

1) Narrowing of Habitat Protections
The new definition of “habitat” under the Species Conservation Act appears to drastically limit protected areas to narrowly defined zones such as active nests or dens. This fails to account for the broader ecosystems that species depend on for survival and recovery (Schedule 6, Section 1). Such a restrictive scope makes effective conservation nearly impossible and puts over 200 already vulnerable species at greater risk.

2) Elimination of Mandatory Recovery Strategies
Bill 5 removes the requirement to develop recovery strategies (currently under ESA Section 11). Recovery strategies are vital for establishing science-based plans to support species’ survival. Their elimination would leave Ontario without coherent conservation roadmaps and contradicts best practices in wildlife management.

3) Discretionary and Developer-Focused Permitting
The expanded ministerial discretion under the proposed legislation allows permits to be issued for harmful activities without independent scientific oversight (Schedule 6, Sections 17–19). Moreover, the “registration-first” approach allows developers to proceed with projects while mitigation measures are still under consideration. This is an unacceptable shift away from the precautionary principle.

4) Creation of Special Economic Zones
Bill 5’s introduction of “special economic zones” where environmental regulations may be suspended (Schedule 9) creates alarming loopholes. These zones risk becoming development hotspots without the normal checks that protect sensitive ecosystems.

5) Weakening of Enforcement Tools
The removal of stop work orders (formerly ESA Section 27) reduces the ability of enforcement officers to respond quickly to violations. This undermines accountability and compliance with even the reduced standards in the new legislation.

Why this matters

Ontario’s natural heritage belongs to all Ontarians, and it is our shared responsibility to steward it wisely. Bill 5 does not represent a balanced approach—it prioritizes economic activity over ecological integrity, undermines conservation science, and strips away vital protections at a time when biodiversity loss is accelerating globally.

I urge the government to withdraw Schedule 6 of Bill 5 and engage in meaningful consultation with ecologists, Indigenous communities, and the public to improve species protections—not erode them.