1) Impacts on Biodiversity…

1) Impacts on Biodiversity and species conservation:
The new law proposed to replace the Endangered Species Act of Ontario (“Species Conservation Act, 2025”) would, if enacted, do the exact opposite of its stated intent. The new proposed law is clearly designed to strip protection altogether from almost all of the critical habitat protected by the Endangered Species Act, 2007, reducing the definition of “habitat” to minute areas of land—the immediate “dwelling place” of an endangered animal (such as around dens or nests) and the immediate “root zone” of an endangered plant. If adopted, this change would surely increase the risk of extinction for endangered and threaten species. One reason for the increase in risk is because a certain degree of ecological or landscape connectivity is needed to maintain populations of species. There needs to be elements on the landscape that allow any given species the ability to move among areas that have resources such as food. Simply protecting “dwelling places” is wholly insufficient and jeopardizes connectivity. For instance, because boreal caribou typically avoid crossing roads, replacing one of their preferred habitats, mature forests, with roads would decrease connectivity for this species where they currently exist. Furthermore, at the 2022 United Nations (UN) Conference of Parties for the Convention on Biological Diversity (CBD), one of the main long-term goals to reverse the decline in biodiversity was that the “integrity, connectivity and resilience of all ecosystems are maintained, enhanced, or restored, substantially increasing the area of natural ecosystems by 2050” (CBD, 2023)

2) Removal of permitting process
Proponents should NOT be able to start work as soon as they are registered. This essentially removes the approval process entirely and incentivizes submission of projects with known impacts on wildlife, because investigation into the impacts will not happen, or the impacts of the proposed projects only known after the work has been completed. This bill is framed as a special tool to fast-track projects that help protect Ontario, the language used is intentionally vague and provides nothing to identify or promote interests for Ontarians. There are no criteria to focus “designated project” or “special economic zones” status on activities or projects necessary to replace U.S. imports with domestic production, connect Ontario producers with new markets or replace U.S. demand for raw materials.
There is no language that would restrict the Premier and Cabinet Ministers’ power to hand immunity to people, projects, lands and circumstances. It would be an unfettered power to pick and choose who our provincial and municipal laws apply to under the guise of ‘economic benefits’. There’s nothing in the Act even to limit its application to the kinds of laws actually relevant to industrial development, land use or infrastructure approvals. The broad power to “exempt” anyone the Premier and Cabinet choose “from requirements under provisions of an Act or of a regulation or other instrument under an Act” would extend to everything from the Trespass to Property Act (the law which prevents strangers from walking into our backyard and refusing to leave) to labour and health and safety laws, to the Highway Traffic Act.