Thank you for the…

Thank you for the opportunity to express my views on Bill 5 and the proposed changes to the Endangered Species Act (ESA). I write as a concerned citizen and rural landowner.
Introduction:
We can all agree that sustainable economic growth in Ontario is a desirable goal. But "sustainable" is the key word; these proposed changes will not sustain endangered species. By attempting to place a much greater emphasis on resource exploitation and economic growth in decisions about species at risk, new development projects in Ontario will likely have greater adverse impacts on species and natural areas.
If the current approach is “complicated” and “takes too long,” as noted in the proposal summary, that is because ecosystems are complicated. It takes time to understand proponents' plans, how those plans may cause harm to natural areas, what at-risk species and their habitats may be affected, and how these competing interests might be balanced. The so-called “new approach” would deviate very much from the intent of and practices under the ESA.
Concerns:
I object to the proposals to amend / replace the ESA with a new Species Conservation Act. Scrapping the ESA and creating regulation-free zones for industry would increase threats to nature and put wildlife at greater risk.
The proposals would gut existing protections for endangered species by creating new special economic zones that are immune to the provincial rules, policies and regulations enforced elsewhere in Ontario. They would give government too much leeway to make unilateral decisions on environmental and ecological issues they know little about; decisions that belong mainly with scientists. In particular, I object to any provincial Cabinet or cabinet minister in charge having discretion to make new regulations or to decide how to classify species at risk. The government should not have discretion to add or remove any species from the list of protected species.
In Ontario alone, more than 230 plants and animals are at risk. (Could the minister responsible name a fraction of them?) These imperiled species rely on healthy forests, waters and wetlands – as do all Ontarians. We need a strong ESA that protects amphibians, birds, fish, insects, lichens and mosses, mammals, molluscs, plants and reptiles.
The existing definitions and protections of the ESA should be retained. Any issues of delays, costs, or lack of clarity can be dealt with through improvements in process.
Ontario’s threatened and endangered species need plans for their survival and recovery. The proposed changes eliminate the requirement to develop recovery plans and propose no meaningful alternative. Without recovery plans, the new Species Conservation Program will not be able to set priorities, and businesses and the public will not have guidance on the most important places to protect and actions to take. Instead, the government suggests it will “focus the development of conservation guidance when and where it is needed and makes sense to do so.” The sentence is vague and seems intended to allow proponents to do as they please.
I urge the government to keep the ESA requirements to develop recovery strategies and management plans, government response statements, and reviews of progress within the legislation.
Concerns about birds:
Regarding birds in particular, Ontario proposes to no longer apply provincial protection to birds and their nests if they are listed under the federal Species at Risk Act. This means the province will no longer have regulatory tools to protect the habitat where threatened and endangered birds nest and feed. Habitat protection will be voluntary on both private and provincial land. The proposed new Species Conservation Act will only provide protection for the “dwelling place” or nest and immediate surrounding, but not the forest, wetland, grassland or other habitat in Ontario that birds require to survive. At a bare minimum, legal protection for threatened and endangered birds should continue to exist for habitat on provincial crown land, just as the federal Species at Risk Act habitat protections apply to federal crown land.
Ontario should protect habitat for migratory birds. I don’t see any plan for this in the proposed legislation and the new Species Conservation Program. Federal laws do not protect habitat for migratory birds on private or provincial crown land, as the government’s rationale for the change incorrectly suggests.
Finding the right balance:
Ontarians place a high value on protecting species at risk, enhancing biodiversity and natural areas, and conserving the environment. All species, including humans, need sufficient habitat, clean air and water to survive and thrive. The existing ESA strikes a reasonable balance between protecting species at risk and enabling economic development through exploitation of natural resources.
I disagree that Bill 5 would provide “a reasonable, balanced approach to protecting species in Ontario.” The proposals clearly weaken protections for species at risk. They tilt the balance too heavily in favour of proponents and development projects, and replace legal requirements with “expectations” and voluntary initiatives.
Conclusion:
I call on the Government of Ontario to cancel Bill 5, drop its plan to introduce “regulation-free zones” for resource extraction, drop its plan to give the government discretion on what species are protected, and stop putting endangered species in even greater danger.
I call on the government to strengthen the Endangered Species Act, invest more in conservation and establish new protected areas to safeguard biodiversity. We are losing species at an alarming rate.
Thank you.