I’m deeply concerned about…

ERO number

025-0380

Comment ID

140994

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

I’m deeply concerned about the proposed “Bill 5” and its implications for the protection of our endangered species. The amendments contained within Schedule 2 of this bill do not merely fail to address the pressing issues raised by environmental organisations and the Auditor General; they represent a significant withdrawal of protections that have been hard-won and critically necessary for the preservation of our biodiversity.

First and foremost, Bill 5 seeks to replace the robust Endangered Species Act (ESA) with a narrower Species Conservation Act, fundamentally altering the purpose of our species protection framework. The new legislation prioritises “sustainable economic growth” over the imperative of safeguarding endangered species. This shift in focus is not just a matter of semantics; it fundamentally undermines the very essence of what the ESA was designed to achieve—protecting those species that are most vulnerable in our ecosystems.

The proposed amendments would drastically narrow the definition of what constitutes an endangered species’ habitat, limiting it to immediate dwellings and surroundings. This exclusion of critical areas needed for the full life cycle of these species is a grave error. Such a definition fails to recognise the interconnectedness of ecosystems and the essential habitats that support the survival of these species.

Moreover, Bill 5 empowers the cabinet to disregard science-based proposals for listing species at risk, allowing for the possibility that non-listed species may receive no protection whatsoever. This is a dangerous precedent that undercuts the role of science in conservation efforts and places our most vulnerable species at even greater risk.

In addition, the removal of the obligation for the government to create recovery strategies and report on recovery efforts represents a troubling retreat from accountability. Without these strategies, we risk losing sight of the necessary steps to aid in the recovery of endangered species, further exacerbating their decline.

The language of the bill also raises significant concerns. The inexplicable removal of the term “harass” from prohibited actions against species at risk is particularly alarming. Harassment can be just as detrimental as physical harm, as it disrupts the essential behaviours necessary for survival. This oversight could lead to increased disturbances in critical habitats, putting additional stress on already beleaguered populations.

Furthermore, the bill proposes to delegate Ministerial powers with virtually unfettered discretion, allowing for a dilution of accountability and oversight. This lack of transparency raises significant questions about the motivations behind such changes and the potential consequences for species protection.

Lastly, I must emphasise that Bill 5 fails to acknowledge the rights of Indigenous peoples, neglecting the Crown’s Duty to Consult and the principles outlined in the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). This oversight not only undermines Indigenous rights but also disregards the invaluable traditional knowledge that Indigenous communities can contribute to conservation efforts.

In conclusion, I urge the Province to consider the ramifications of Bill 5 on our natural heritage. The proposed amendments threaten to weaken the protections that are essential for the survival of endangered species, and in doing so, they jeopardise the health of our entire ecosystem. We must advocate for a legislative framework that prioritises the preservation of our biodiversity, respects Indigenous rights, and upholds our responsibility to future generations. Ontarians must stand firm in our commitment to protecting the natural world that sustains us all.

Schedule 2 of Bill 5 should be immediately withdrawn by the Ontario government. The Ministry of the Environment, Conservation and Parks should instead establish an open and accessible process for developing appropriate ESA amendments which help achieve the statute’s current purposes of protecting and promoting the recovery of species that are at risk.