Comment
Bill 5 will eliminate much of the current legislation and remove most of the environmental protection need to protect many species of birds that inhabit territories within Ontario. Any proposed new legislation will not offer the strong protection that many species especially endangered species that are urgently needed.
Ontario should protect habitat for migratory birds, and I don’t see any plan for this in the proposed legislation and the new Species Conservation Program.
The proposed new Species Conservation Act will only provide protection for the “dwelling place” or nest and immediate surrounding, but not the forest, wetland, grassland or other habitat in Ontario that birds require to survive. Federal laws do not protect habitat for migratory birds on private or provincial crown land, as the government’s rationale for the change incorrectly suggests.
The existing habitat definition and protections of the Endangered Species Act should be retained. They provide a clear approach to conserving Ontario’s most at-risk birds, and any issues of delays or lack of clarity can be dealt with through improvements in process.
At a bare minimum, legal protection for threatened and endangered birds should continue to exist for habitat on provincial crown land, just as the federal Species at Risk Act habitat protections apply to federal crown land.
Incentives for habitat protection on private land must include funding for conservation easements and purchase of land by land trusts, and the annual budget of the new Species Conservation Program should be sufficient to make this meaningful.
Ontario’s threatened and endangered birds need plans for their survival and recovery. The proposed changes eliminate the requirement to develop recovery plans and propose no meaningful alternative. Without recovery plans, the new Species Conservation Program will not be able to set priorities, and businesses and the public will not have guidance on the most important places to protect and actions to take.
Indigenous leadership, voices, knowledge, and ongoing work on the land are critical for wild birds to thrive in sustainable ecosystems. The proposed legislation must respect Indigenous rights and the duty to consult.
Submitted May 11, 2025 8:03 PM
Comment on
Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025
ERO number
025-0380
Comment ID
139996
Commenting on behalf of
Comment status