To whom it may concern, I am…

To whom it may concern,

I am writing to discuss Bill 5, the Protect Ontario by Unleashing Our Economy Act and why I think this act does not protect Ontario but instead harms it by weakening environmental protection policies, leading to negative long term consequences for positive short term gains.
Firstly, I understand that there are many valid criticisms of the current system including the need for double documentation for approvals at both the federal and provincial level making the processes less expedient than they could be (Singh, 2025). However the focus of this bill seems entirely placed on making approval and building processes more expedient instead of improving the system as a whole. In short, this bill proposes that projects are “faster” but does nothing to insure that the projects are “better”.
One key point that the province has provided in their reasoning for the changes to the Endangered Species Act is that there was a lot of uncertainty over the definition of a habitat, causing delays in building due to poorly defined requisite protection measures (Singh, 2025). I agree that it is often difficult to define concretely the extent of an animal’s habitat, however I believe that we should use the precautionary principle in these cases to protect areas of potential habitat, rather than only guaranteed habitat (Kriebel et al., 2001).
The proposed narrowing of the definition of habitat to refer only to the area immediately around an animal’s living space does a disservice to those who worked on the previous legislation and will result in small pockets of animal dens that cannot survive in an area that has largely been developed (Bowman, 2025). Instead I believe that the definition of habitat should also include at minimum, an animal’s feeding ground as well as an animals home range, the area that it travels in day to day activities. To put this into perspective I think that a human’s habitat should not just include their bedroom, but instead also the house where they make their food, and at minimum the neighbourhood in which they travel or daily activities such as school or work. The proposed definition of habitat limits a human’s habitat to only their bedroom, an area which they will not be able to survive in long without access to their wider habitat. On a species by species basis it may also be necessary to consider areas or routes of migration as well as nesting areas.
Additionally, this act proposes the removal of recovery and stewardship as goals in favour of protection and conservation (Peiman, 2025). In effect this change is stating that the current state of a given species population is what is desirable and efforts should not be made to improve their circumstances. This means that the proposed legislation views maintaining a given species place on the endangered species list as a desirable outcome so long as it does not worsen. While I do think that protection and conservation are important, I think that we should be striving to improve circumstances and should recognize that the current state of many species is far from ideal. We should endeavour for projects to improve upon and make a commitment to sustainability and desirable futures, rather than simply avoiding harm.
The power for the provincial government to create special economic zones is worrisome and has the potential to be abused not just by this government, but any future government, by granting the power to ignore laws in certain areas (Bowman, 2025). Because these special economic zones allow governments to bypass laws it runs the risk of having governments decide that any area in which they could not obtain legal approval for will be designated as one of these zones.
Finally, the name of the act “Protect Ontario by Unleashing our Economy” is misleading and seems to attempt to invoke a fear based response by implying that Ontario needs protecting. Most likely this is an attempt to capitalize on the current tensions with the United States to pass a bill with many broad sweeping changes. I believe that the government should attempt for more honest titles of bills in the future such as “Reducing Environmental Barriers to Project Approval”.

References

Bowman, L. (2025, May 6). Ford’s omnibus bill guts environmental protections. Ecojustice. https://ecojustice.ca/news/demystifying-bill-5-how-doug-fords-omnibus-b…
Kriebel, D., Tickner, J., Epstein, P., Lemons, J., Levins, R., Loechler, E. L., Quinn, M., Rudel, R., Schettler, T., & Stoto, M. (2001). The precautionary principle in environmental science. Environmental Health Perspectives, 109(9), 871–876. https://doi.org/10.1289/ehp.01109871
Peiman, K. (2025, April 24). Ontario is killing its Endangered Species Act. The Narwhal. https://thenarwhal.ca/ontario-endangered-species-act-repealed/
Singh, I. (2025, April 30). Ontario is scaling back species at risk protections, worrying advocates and inviting federal intervention | CBC news. CBCnews. https://www.cbc.ca/news/science/ontario-species-at-risk-changes-1.75222…