The Ontario Regional…

The Ontario Regional Committee of the Canadian Association of Physicians for the Environment (CAPE Ontario) respectfully submits its formal comments on the proposed interim changes to the Endangered Species Act, 2007 and the proposed Species Conservation Act, 2025, outlined in Schedule 10 of Bill 5—the proposed Protect Ontario by Unleashing Our Economy Act.

CAPE is a non-partisan, physician-led organization with over 36,000 supporters across the country. It plays a unique role at the intersection of health, environment, and justice, bringing a credible, evidence-based perspective delivered by the trusted voices of doctors, other health professionals, and researchers to support community and planetary health.

As physician advocates for human health through the protection of environmental health, we do not support the passage of Bill 5 or the Schedule 10 proposal to repeal the Endangered Species Act and replace it with the Species Conservation Act.

The proposed Species Conservation Act is deeply inadequate, relying on voluntary, deregulated measures overseen by non-experts—including actors from business and industry. This approach threatens biodiversity by significantly weakening protections for multiple at-risk species in Ontario. In turn, biodiversity loss poses serious and far-reaching threats to both environmental and public health.
The proposed Species Conservation Act, particularly when compared to the current Endangered Species Act, would critically weaken protections for at-risk species through multiple mechanisms that are not grounded in science or evidence. Control would be shifted to industry, developers, and other stakeholders with vested interests, while permitting would become less regulated and left to the discretion of the Minister of the Environment, Conservation and Parks. The proposal aims to eliminate the current expert-driven, mandatory listing and tracking of species at risk in favor of a voluntary registry. If species at risk are not properly identified, tracked, or even officially listed, they will not be protected.

Additionally, the proposal threatens to dismantle key safeguards, including habitat protections, prohibitions against species harassment, and the implementation of species recovery strategies.
Multiple expert analyses of Schedule 10 of Bill 5 conclude that these proposals will harm biodiversity and accelerate the extinction of key species at risk in Ontario. As the World Health Organization has stated, biodiversity “underpins all life on Earth.” Failing to protect it can lead to serious consequences for human health, including increased rates of infectious disease, food insecurity, and more. Human well-being is deeply interconnected with the health of other species. When ecosystems are disrupted and species fail to thrive, the impacts extend to human health and can result in significant economic consequences.

CAPE Ontario recognizes the urgent need to protect biodiversity by safeguarding species at risk, as a means of mitigating harm to the environment, human health, and the economy in Ontario. The proposed replacement of the Endangered Species Act, 2007 with the Species Conservation Act, 2025 would severely weaken protections and further endanger species at risk. This poses an unacceptable risk to the health and wellbeing of the people of Ontario. Therefore, as concerned physicians and health professionals living and working in Ontario, we oppose the interim changes and proposed repeal of the Endangered Species Act of 2007, and oppose the passage of the Species Conservation Act.