Comment
We are calling on the Ontario Government to not proceed with Bill 5, strengthen your commitment to science-based conservation and improve rather than hinder the state of biodiversity in the province
Replacing the ESA with a significantly weaker Species Conservation Act is irresponsible, short sighted and will negatively impact species at risk and their habitats which is in opposition to the Accord for the Protection of Species at Risk which the province of Ontario had committed to.
Government should not have the discretion to add or remove extirpated, endangered, and threatened species to remove species from the list of protected species. COSSARO must be a strong committee, with members chosen solely for their scientific taxonomic expertise to assess species on the biological risk of extinction which then are added to the species at risk list without political interference.
The proposed definition of habitat reduces protection to the point in being ineffective. The proposed definition should not be pursued.
Removing species protections for SARA protected aquatic species and migratory birds fails to recognize the provincial responsibility to species at risk and their habitat. These species must remain in the Ontario endangered species legislation.
Removal of recovery strategies and Government Response Statements is highly problematic. This removes transparency and obligation for the provincial government to commit to any action to recover species at risk.
Winding down of the Species at Risk Program Advisory Committee will reduce accountability and transparency on how the province manages species at risk.
Establishing a new Species Conservation Program and increasing the investment to support conservation activities is the only good piece of Bill 5 that demonstrates a potential benefit for species at risk.
As opposed to winding down of the Species Conservation Fund, this fund should be properly implemented and managed but the independent agency with a requirement to start providing funds in the current fiscal year.
The registration-first approach is highly concerning, should not be pursued and the existing implementation of it should be rolled back. Developers should at no point in time be exempt from review and approval for activities that would kill or harm an Endangered or Threatened species or destroy their habitat.
Compliance and enforcement of severely weakened protection is not the solution to species at risk conservation and recovery. The province’s focus needs to be on strengthening conservation action along with oversight and limiting industrial and residential development, not enforcing very limited laws.
Supporting documents
Submitted May 17, 2025 7:12 PM
Comment on
Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025
ERO number
025-0380
Comment ID
148325
Commenting on behalf of
Comment status