Schedule 10 - Proposed…

Schedule 10 - Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025

Schedule 10 Should be Withdrawn!

A close examination of the SCA reveals that its statutory regime is even weaker and more problematic than the current or amended ESA.
1. Unacceptable and Inconsistent Statement of Purpose
2. Problematic Definition of “Habitat” under the SCA
3. Ineffective Non-Derogation Clause
4. Unjustified Non-Application of the SCA to Migratory Birds and Aquatic Species
5. Restricted COSSARO Role and Permissive Species Listing Authority
6. Removal of Traditional Prohibitions Against Harm and Habitat Destruction
7. Erroneous Inclusion of “Mistake of Law” Defence

Bill 5 will unleash significant problems by undermining procedural and substantive provisions of
various environmental, species, and heritage protection laws in a manner that will introduce
material economic, environmental, social, and cultural uncertainty, as well as derogate from the
legal and constitutional rights of members of the Ontario public, including Indigenous peoples,
particularly vulnerable to such actions.

In short, the Ontario legislature should take care that special economic zones created under the authority of Bill 5 do not end up being little more than law-free sacrifice zones that severely impact the most vulnerable in Ontario society.

I am strongly opposed to all of the Bill 5 schedules. All schedules, with minor exceptions, should be withdrawn and not further considered by the Legislative Assembly of Ontario until they are substantially modified to ensure robust protection for the environment, human health, and vulnerable members of the Ontario public, including Indigenous peoples, who may otherwise be harmed by the amendments contained in the various schedules.