## Comment Opposing Bill 5:…

## Comment Opposing Bill 5: Protect Ontario by Unleashing our Economy Act, 2025

I strongly oppose the proposed changes to the Endangered Species Act (ESA) and the introduction of the Species Conservation Act (SCA) as outlined in Bill 5. These amendments represent a significant weakening of protections for Ontario’s most vulnerable species and their habitats. Below are key concerns and supporting facts:

**1. Shift to a Registration-First Approach Weakens Oversight**

The proposal to move from a permit-based system to a “registration-first” approach would allow most activities that could harm species at risk to begin immediately after online registration, with little to no prior review by ministry experts. This dramatically reduces the opportunity for careful, science-based assessment of potential impacts before damage occurs. The current permit system, while sometimes slow, ensures that activities are scrutinized for their effects on endangered species before they proceed-an essential safeguard that will be lost under the new approach[1][2].

**2. Narrowing the Definition of Habitat Puts Species at Greater Risk**

The redefinition of “habitat” to only include the immediate area around a dwelling place such as a nest or den, or the critical root zone for plants, ignores the broader ecological requirements of species. Many species rely on larger landscapes for foraging, migration, and seasonal activities. By restricting legal habitat protections to these narrowly defined areas, the bill would leave much of the territory essential for species’ survival unprotected, increasing the risk of further declines and extinctions[1][2].

**3. Removal of “Harass” From Protections Reduces Safeguards**

The elimination of “harass” from the list of prohibited activities means that disruptive actions that do not directly kill or injure species-but still negatively affect their survival-may no longer be illegal. Harassment can include noise, light, or other disturbances that prevent breeding or cause stress, which are well-documented threats to at-risk species[1][2].

**4. Increased Government Discretion Undermines Science-Based Decision-Making**

While the Committee on the Status of Species at Risk in Ontario (COSSARO) will continue to assess species, the government will now have full discretion to add or remove species from the protected list, regardless of COSSARO’s recommendations. This opens the door to political or economic considerations overriding scientific evidence, undermining the integrity of Ontario’s species-at-risk program[1][2].

**5. Elimination of Recovery Strategies and Progress Reviews Reduces Accountability**

The removal of requirements to develop recovery strategies, management plans, and progress reviews means there will be less transparency and accountability in how species are protected. These documents are critical for tracking progress, identifying threats, and ensuring that government actions are effective and evidence-based[1][2].

**6. Reduced Protections for Migratory Birds and Aquatic Species**

By excluding migratory birds and aquatic species already protected under the federal Species at Risk Act from provincial protections, the bill creates gaps in oversight and may lead to weaker enforcement and protection on non-federal lands[1][2].

**Conclusion**

Ontario’s endangered species and their habitats are already under immense pressure from development and climate change. The proposed changes prioritize short-term economic gains over the long-term health of our ecosystems. I urge the government to reconsider these amendments and maintain strong, science-based protections for species at risk in Ontario.

**Protecting biodiversity is not a barrier to progress-it is essential for our province’s environmental, economic, and social well-being.**

Sources
[1] 025-0380 https://ero.ontario.ca/notice/025-0380