I am writing this comment on…

I am writing this comment on Bill 5, the Protect Ontario by Unleashing our Economy Act, 2025, to communicate my concerns about the proposed Act as an Ontario citizen. I believe that if Bill 5 passes, it will substantially weaken protections for Ontario’s species.

The Ontario government’s proposal for this bill states that the current Endangered Species Act, 2007 makes the process of obtaining a permit slow and complex, and “[causes] unnecessary delays and costs for housing, transit, and critical infrastructure”. I strongly object to this statement. On the contrary, it is perfectly necessary to take time to develop a thorough understanding of an area, its species, and its vulnerabilities before subjecting it to development. It is true to say that this process is slow and complex, it is meant to be. It is crucial to determine possible significant negative effects of a proposed project, especially long-term and cumulative effects that require a comprehensive analysis to understand. When it comes to endangered species, adequate time must be taken to provide them with special consideration in order to help their populations recover. It would be impetuous to try to rush such necessary processes that greatly help to protect our native species.

My greatest concern is about the change in the definition of habitat that would occur due to the proposed repeal of the Endangered Species Act, 2007 and the creation of the Species Conservation Act, 2025. The current definition of habitat in the Endangered Species Act, 2007, is:

(a) with respect to a species of animal, plant or other organism for which a regulation made under clause 56 (1) (a) is in force, the area prescribed by that regulation as the habitat of the species, or

(b) with respect to any other species of animal, plant or other organism, an area on which the species depends, directly or indirectly, to carry on its life processes, including life processes such as reproduction, rearing, hibernation, migration or feeding,

and includes places in the area described in clause (a) or (b), whichever is applicable, that are used by members of the species as dens, nests, hibernacula or other residences

Bill 5 proposes to minimize this definition to only include:

for animal species: a dwelling place, such as a den, nest, or similar place, occupied or habitually occupied by one or more members of a species for the purposes of breeding, rearing, staging, wintering, or hibernating; the area immediately surrounding a dwelling place described above that is essential for the purposes mentioned

for vascular plant species: the critical root zone surrounding a member of the species

Bill 5 greatly narrows the definition of habitat to specifically include only a species’ dwelling and the area immediately surrounding the dwelling. It erases the details included in the current Endangered Species Act definition, the areas that species use directly and indirectly to carry on their life processes, including for migration and feeding. The new proposed definition mentions staging areas as being part of habitat—as in areas that migratory birds stop to rest and feed—but does not consider wider migration ranges required by terrestrial animals. Animal species can have wide and unpredictable home ranges, especially larger mammals that travel long distances, so the unique habitat needs of those species should be considered in the definition. For example, a female black bear in Ontario requires a home range of around 10 to 80 square kilometers to feed and mate, den, and rear offspring, and a male often requires an even greater area. Because of these factors, I suggest that the current broad definition of habitat be retained. The proposal for Bill 5 states that the new definition acts to preserve core elements of species’ habitat to provide greater clarity to proponents, but I strongly believe it confines the habitat of species to an unacceptable degree and shows a complete lack of respect for the spatial needs of different species.

A lot of our endangered species have become endangered due to urban and industrial development which encroaches on their habitat. Therefore, one of the best ways to protect endangered species and help them recover is to limit developmental projects in their habitats. Bill 5 will do the opposite of this by reducing restrictions for developmental projects and rushing the process of initiating a project. This is another reason why I urge the Ontario government to withdraw Bill 5.

Even in an economic crisis, such as what we are experiencing now, we as Canadians should continue to put our environment and vulnerable species first. It is these native species and the healthy environment they create that will ensure the enduring health of Ontario citizens and all Canadians. Environments that are rich in native plants and animals provide clean air, clean water, healthy food, medicines, and other essential resources. We must not act solely for the needs of current generations, but also for the needs of future Canadians. Bill 5 may be very successful in unleashing Ontario’s economy in the short-term, but it would destroy any chance of Ontario maintaining a good economic and environmental state in the long-term. The bill would make it easier to exploit Ontario’s natural resources without proper forethought and careful planning and execution. If passed, it will surely lead us to having more extirpated and endangered species than ever before.

Canada is home to the largest area of intact boreal forest on Earth, the Great Lakes Region, the Canadian Shield, and Niagara Falls, and a diverse array of terrestrial and marine ecoregions, including tundra, prairies, coastal rainforest, montane cordillera, Arctic cordillera, mixed-wood forests, and Pacific, Arctic, and Atlantic coastal environments. Canadians should be able to look proudly to a future where our unique collection of lands, waters, and species are safeguarded. Do not let our beautiful country become a wasteland.