I strongly oppose Bill 5 and…

I strongly oppose Bill 5 and the proposed repeal of the Endangered Species Act, 2007 in favor of the Species Conservation Act, 2025. The proposed changes place an undue level of trust in building developers to act in good faith, while significantly reducing the oversight, accountability, and precautionary measures that are essential to protecting Ontario’s biodiversity.
1. Registration-First Approach Lacks Accountability

"Ultimately shift nearly all species-related authorizations to a registration-first approach..."

This fundamentally weakens protections. Under the new model, developers can begin work immediately after registering online — without prior review, site assessment, or government confirmation. This “dig first, check later” approach risks irreversible harm to species and habitats before any mitigation measures are considered. It effectively removes the government's ability to act before damage is done. There is no clear explanation of what body will proactively verify compliance, how monitoring will occur, or how violations will be identified and penalized in a timely manner.

The proposal claims this approach has worked for other environmental authorizations, yet no evidence or examples are provided to justify its effectiveness in protecting at-risk species.
2. "Clear Expectations" Still Allow Harm by Default

"Establish a framework for setting clear expectations and rules for proponents to follow..."

This language suggests that only activities deemed likely to cause direct harm will be regulated. That excludes many real ecological threats such as habitat fragmentation, pollution, noise, or cumulative impacts — which are not “direct” but still devastate ecosystems. This framework hands more power to developers while reducing provincial oversight, particularly for activities tied to government-prioritized projects like housing and infrastructure.
3. Voluntary Conservation Cannot Replace Legal Protections

"Establish a new Species Conservation Program to support voluntary initiatives..."

Replacing robust permitting with voluntary programs and restoration incentives weakens the government’s legal responsibility to enforce species protections. Developers can destroy habitat, register afterward, and potentially participate in optional conservation efforts — which are unlikely to replace the lost ecological function. Without mandatory, science-based approvals in advance, the species at risk may already be gone by the time enforcement kicks in.
4. "Stronger Enforcement" Is Misleading

"Strengthen our ability to enforce species protection laws..."

This claim is contradictory. The government cannot meaningfully strengthen enforcement while simultaneously reducing its role in approval, review, and oversight. If developers are presumed compliant by default, and there is no permit-based review process, the threshold for enforcement is significantly raised — it requires visible, reportable harm that has already occurred.

Moreover, removing proactive recovery planning, habitat mapping, and scientific assessments further limits the government’s capacity to prevent species decline.
Conclusion

This proposal does not represent a “balanced approach.” It prioritizes development speed and cost-efficiency over ecological stewardship, despite Ontario’s global responsibility to protect its diverse natural heritage. Without proper oversight mechanisms, site-specific scientific assessments, and enforceable pre-approval processes, this bill is a blueprint for extinction by convenience.

I urge the government to withdraw Bill 5 and commit to strengthening — not dismantling — our species protection framework.