Dear Minister. RE:…

Dear Minister.

RE: Protecting Ontario's Economic and Environmental Legacy: A Technology-Driven Approach to Conservation and Development

I am an established ecologist with deep expertise in Ontario’s natural heritage systems, with a professional background that includes over two decades of experience and extends across ecological assessment, land use planning, growth management, and environmental policy. Over the course of my career, I’ve worked at the intersection of science and development, helping to shape projects that balance ecological integrity with economic progress. I understand the practical needs of infrastructure, housing, and community growth—and I firmly believe that a well-designed ecological study does not need to slow down or add unnecessary risk to the approvals process. What’s critical is that we adopt efficient, transparent, and evidence-based approaches that capture diverse forms of knowledge—scientific, technical, and Indigenous—and that these efforts can proceed in parallel with the necessary engineering and infrastructure planning that is required to reduce a variety of risks. Nature is resilient, but that resilience relies on sound decisions grounded in rigorous study and policy frameworks that foster both accountability and long-term sustainability.

I am writing to express significant concerns regarding Ontario's Bill 5, Protect Ontario by Unleashing Our Economy Act, 2025, which proposes the repeal of the Endangered Species Act, 2007 (ESA) and its replacement with the Species Conservation Act (SCA). While I understand the government’s ambition to foster economic growth through streamlined regulatory processes, I believe unintended consequences of the proposal will undermine Ontario's reputation as a leader in sustainable development. More critically, it threatens market access, investment opportunities, Indigenous rights, and international trade relationships that rely on strong environmental leadership, stewardship. and equitable resource management.

Ontario's natural resources—forestry, mining, and agriculture—are vital to the provincial economy, contributing billions annually and supporting thousands of jobs. However, access to key international markets, including the European Union, the United Kingdom, and the United States, is contingent upon sustainable sourcing and responsible environmental management. The proposed changes under Bill 5, particularly the narrowed definitions of "habitat" and the introduction of discretionary government authority over species protection, are likely to conflict with international standards. Many global markets require certification under initiatives like the Forest Stewardship Council (FSC) and the Sustainable Forestry Initiative (SFI), which demand robust biodiversity protections. The proposed changes to Ontario's regulatory framework risks the decertification of its natural resource products, jeopardizing export agreements and damaging its standing as a sustainable producer. At a minimum, Bill 5 will create a period of uncertainty regarding well established and accountable regulatory frameworks.

The repeal of the Endangered Species Act through Bill 5 poses significant risks to Ontario's commitment to the Convention on Biological Diversity (CBD), particularly its Kunming-Montreal Global Biodiversity Framework, which was notably developed here in Canada. This landmark agreement sets ambitious global targets to halt and reverse biodiversity loss by 2030, including the protection of 30% of global land and marine areas. By narrowing habitat definitions and reducing automatic protections for species at risk, Bill 5 directly contradicts the principles of ecosystem restoration and species recovery outlined in the framework. As the host nation for the Kunming-Montreal agreement, Canada has a unique responsibility to lead by example, and Ontario's legislative shift risks undermining this leadership on the global stage, weakening international confidence in our environmental stewardship.

Moreover, the global financial community is increasingly aligning with the Taskforce on Nature-related Financial Disclosures (TNFD), emphasizing transparent reporting of nature-related financial risks. Ontario's rollback of species protections could lead to the reclassification of resource-based projects as high-risk investments, potentially deterring international capital and inflating borrowing costs for Ontario-based enterprises. If Ontario is perceived as neglecting ecological stewardship, it may also face divestment from institutional investors prioritizing Environmental, Social, and Governance (ESG) criteria. In a time when sustainable finance is becoming increasingly significant, weakening protections for species at risk could lead to a loss of investor confidence and competitive disadvantage in global markets.

In Ontario, the repeal of the Endangered Species Act through Bill 5 may further exacerbate concerns over inadequate consultation and revenue sharing with Indigenous treaty holders, potentially violating principles of Free, Prior, and Informed Consent (FPIC) under the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). This legislative shift could weaken environmental protections and diminish Indigenous oversight on Crown land, indirectly mirroring issues seen in the softwood lumber disputes where underpayment has been perceived as a subsidy. Such regulatory rollbacks may also amplify trade tensions with countries like the United States, which have historically imposed tariffs on Canadian softwood lumber, arguing unfair subsidies due to low stumpage fees and insufficient compensation to Indigenous communities. In this context, Ontario Bill 5 could contribute to trade vulnerabilities by intensifying criticisms of unbalanced resource management and Indigenous rights violations.

Instead of repealing effective legislation and policy frameworks, I propose that Ontario embrace a technology-driven approach to modernize conservation practices, ensuring both economic growth and environmental sustainability. Emerging technologies such as Artificial Intelligence (AI), Machine Learning (ML), and Geographic Information Systems (GIS) have the power to transform environmental assessments and habitat protection strategies. By leveraging these tools, Ontario can pioneer Next-Generation Environmental Assessments (NGEA) that are faster, more accurate, and more transparent. Predictive analytics powered by AI can anticipate changes in species populations and habitat conditions, while GIS mapping and LiDAR technology can monitor environmental impacts in real-time. This data-driven approach would not only support sustainable development but also enhance regulatory compliance and market confidence. I believe this would be supported by many stakeholders, including our new Federal Government.

In addition to modernizing assessments, Ontario should double down and commit to being a global leader in establishing technology-enhanced habitat protection mechanisms. AI-driven analytics can identify critical ecological corridors, breeding grounds, and seasonal habitats that are essential for species survival. Digital habitat banking and blockchain technologies can bring transparency and traceability to conservation efforts, allowing developers to invest in offset programs that ensure a net-positive environmental impact. These measures would align Ontario’s policies with international conservation expectations, reinforcing its reputation as a responsible global supplier.

Further, I recommend that Ontario mandate real-time environmental monitoring for all major development projects. Internet of Things (IoT) sensors, satellite imagery, and digital twin ecosystems can provide continuous data on habitat health, water quality, and species viability. Automated triggers could be set to deploy mitigation measures immediately if ecological thresholds are crossed, preventing irreversible damage and maintaining ecosystem integrity. These technologies are already used to safeguard biodiversity on small scale projects; certainly there is an ability to scale their use to larger, more complicated, projects. Doing so would elevate the credibility of Ontario through increasing the transparency of environmental compliance with international trade and sustainability standards.
Ontario has long been recognized for its commitment to balancing economic development with ecological preservation. From the Greenbelt Plan to sustainable forest management initiatives, Ontario has set benchmarks for responsible growth that have been acknowledged globally. Repealing the Endangered Species Act without integrating modernized, technology-driven conservation measures risks undoing this progress. More importantly, it risks diminishing Ontario’s standing in international markets that prioritize sustainability and fair resource management, especially in light of obligations to Indigenous treaty holders and the global community.

I urge the Ministry of the Environment, Conservation and Parks to consider a legislative amendment to Bill 5 that reflects Ontario's long-standing commitment to ecological stewardship while embracing new processes and technologies that enable responsible growth. I welcome the opportunity to discuss these recommendations further and provide insights on how Ontario can lead in sustainable resource management, setting a model for responsible development across Canada.

Thank you for your attention to this critical matter.