Introduction: Thank you for…

Introduction:
Thank you for the opportunity to comment on Bill 5 and the sweeping changes it proposes to Ontario’s environmental legislation. I am a student in the Faculty of Environment at the University of Waterloo and a resident of Vaughan, Ontario. I am speaking not only as someone who studies the environmental impacts and restoration, but also as a citizen deeply invested in the future of this province. Bill 5, under the guise of economic development, proposes the most dangerous dismantling of environmental protections in Ontario’s history. It endangers vulnerable species, erodes Indigenous rights, and centralizes power in profoundly undemocratic ways. This legislation, if passed, would be a defining step backward for Ontario’s environmental legacy and public trust.

Comment 1: The Repeal of the Endangered Species Act (ESA)
The most glaring threat posed by Bill 5 is the full repeal of the Endangered Species Act, 2007—a landmark law that was created to shield the province’s most vulnerable wildlife from extinction. In its place, the bill introduces the so-called Species Conservation Act, which drastically undermines the scientific, legal, and moral framework for species protection. Recovery—the very essence of conservation—is entirely removed from the law’s objectives. Species will no longer be safeguarded to stabilize or rebuild populations. Instead, the new framework abandons the idea that we have any responsibility to ensure a future for these species at all.

Even more concerning is that decisions regarding which species merit protection will now lie in the hands of Cabinet ministers, not scientists. This shift politicizes conservation and opens the door to arbitrary, interest-driven choices instead of evidence-based decisions. This is not environmental governance—it is political interference in science. Furthermore, the bill redefines the concept of "habitat" in dangerously narrow terms, limiting it to immediate structures like dens or nests. Gone are the broader ecosystems—wetlands, forests, migratory corridors—that species actually depend on to survive. This redefinition is not only ecologically inaccurate but deeply misleading, especially for migratory or nomadic species. It effectively renders large-scale habitat protection meaningless.

The bill also removes key mechanisms for enforcing species recovery, such as timelines, legal obligations, and clear conservation goals. Environmental organizations and scientists will no longer have the tools or legal backing to intervene in the decline of species. In one legislative move, Ontario would go from having one of the most comprehensive species-at-risk laws in Canada to having one of the weakest. This is not modernization—it is erasure.

Comment 2: The Threats to the Rights of Indigenous Peoples
Beyond its environmental consequences, Bill 5 represents a direct assault on Indigenous rights and sovereignty. The bill enables developers to bypass environmental assessment processes entirely. Under the proposed system, companies would merely need to fill out an online form, after which they could begin construction, including activities that destroy habitats, kill at-risk species, or permanently damage sacred Indigenous lands. There is no clear path for consultation, no duty to accommodate, and no process that respects the rights guaranteed under Section 35 of the Constitution. The result is a system designed to facilitate industrial expansion at the expense of First Nations’ lands, cultures, and livelihoods.

While the government claims it will fulfill its constitutional duties, the bill’s text says otherwise. The newly created Special Economic Zones Authority (SEZA) includes no meaningful mechanisms for Indigenous governments to participate in or even be informed of decisions affecting their territories. This approach reverses the duty to consult and places the burden of defense squarely on First Nations. Communities will be forced to use their own limited resources to protect their lands from development that has already been approved behind closed doors. The legal remedies available under SEZA are unclear and severely limited. This is not consultation—it is dispossession.

Comment 3: The Creation and Implementation of Special Economic Zones (SEZs)
Bill 5 further exacerbates these issues through the creation of “Special Economic Zones,” areas in which Cabinet can unilaterally suspend provincial and municipal laws. These zones are, in effect, lawless enclaves designed to benefit industry and suppress oversight. They concentrate power in the executive branch, bypassing public consultation, municipal governments, Indigenous leadership, and environmental review processes. These zones have been used globally in authoritarian regimes with catastrophic social, environmental, and human rights outcomes. Ontario is now proposing to replicate this failed model.

Perhaps the most troubling example is the proposal to declare the Ring of Fire a Special Economic Zone. This ecologically critical region, rich in biodiversity and home to numerous Indigenous communities, would be stripped of environmental protections. The proponent of the Eagle’s Nest mine—Wyloo—would be exempted from conducting an environmental assessment. This is an egregious violation of the precautionary principle and a direct threat to the environmental integrity of Northern Ontario. Justifying this radical move by citing a trade dispute with the United States is not only intellectually dishonest—it is dangerous. The claim that weakening environmental protections will somehow resolve economic pressures is both unsubstantiated and shortsighted. What this bill enables is unchecked extraction, not sustainable development.

Bill 5 is not about progress. It is about deregulation, disenfranchisement, and destruction. It silences scientists, undermines Indigenous rights, and exposes some of Ontario’s most vulnerable species and ecosystems to irreversible harm. It reduces conservation to a political bargaining chip and centralizes power in ways that should alarm every Ontarian, regardless of their political affiliation.

Conclusion:
I urge you in the strongest possible terms to reject Bill 5. Ontario has a duty to protect its natural heritage, uphold constitutional rights, and base its decisions on science, not political expediency. This legislation would leave a legacy of degradation, not prosperity. For the sake of the land we live on, the species we share it with, and the generations that will come after us, Bill 5 must not be allowed to pass.