I am writing to express my…

I am writing to express my concerns regarding Bill 5. I hold a Master of Science in Biology, with a thesis focused on fish spawning habitat restoration of a species of Special Concern in Ontario systems. Importantly for Bill 5, I also have previously assessed the proponent-driven process for endangered species threat mitigation for an Endangered species. I have significant expertise in the field of aquatic biology and habitat restoration, and have substantial concerns with Bill 5 in its current form.

Bill 5 proposes to narrow the definition of "habitat" to include only a species “dwelling-place” – their den, nest, or other similar place used for the purposes of breeding, rearing, staging, wintering, or hibernating, as well as the immediate space around it. This changes the current definition, which includes areas used at any point in a species life cycle. The narrowed definition excludes critical areas such as spawning grounds, feeding areas, and migratory routes, which are essential for the survival and reproduction of fish and other species. My research has demonstrated the importance of these habitats in maintaining healthy fish populations in Ontario systems.

The current ESA prohibits activities that kill, harm, harass, capture, or take a species at risk, as well as damage or destruction of their habitat. Bill 5 removes “harass” from the list of prohibited activities and allows proponents to begin activities immediately after registering, reducing oversight and review, which could lead increase the risk of harm to species and their habitats. For example, the proposed Highway 413 route passes through areas where Eastern Massasauga rattlesnake, a Species at Risk (Endangered and Threatened populations) are known to live. The building of this highway without proper environmental reviews could lead to habitat loss, fragmentation, and increases in mortality via roadkill. In addition, the Massasauga in First Nations tradition, is the medicine protector of the land and a reminder to tread lightly and to take only what we need. This is a lesson important to this discussion to ensure our Province is sustainable for future generations.

Bill 5 would grant the Provincial Government the discretion to add or remove species from the Species at Risk in Ontario (SARO) List, reducing the role of the Committee on the Status of Species at Risk in Ontario (COSSARO). The COSSARO is an independent body of experts that assess and classify species based on scientific data and evidence. Under the current ESA, decisions to add or remove species from the SARO List are based on rigorous scientific assessments, ensuring evidence-based decision-making. In Bill 5, COSSARO’s decisions can be overridden by the Provincial Government, undermining scientific integrity of processes and allows for political considerations to influence decisions rather than scientific evidence.

I understand the important of economic growth and infrastructure development. However, these can be priorities that are not mutually exclusive with environmental sustainability and protection. While streamlining processes and improving efficiency are important, they should not come at the expense of thorough environmental reviews. The complexity and time required for current processes are reflective of the need for careful consideration and scientific evaluation to ensure that development does not irreparably harm our natural heritage. Simplifying processes should not mean weakening the safeguards that protect our biodiversity. Our natural heritage and biodiversity, at a time of historic biodiversity declines, is of utmost importance to protect for future Ontarians. I, like many Ontarians, gained a love for the outdoors through camping in Provincial Parks and enjoying our beautiful inland lakes and wetlands. I urge this Government to reconsider the proposed changes in Bill 5 and to prioritize the protection of endangered species and their habitats.

Thank you for your consideration of the above comments.