I am writing to express my…

I am writing to express my deep concern regarding the proposed changes outlined in Bill 5, the Protect Ontario by Unleashing Our Economy Act, 2025. In particular, I’m alarmed by the plan to repeal the Endangered Species Act, 2007 (ESA) and replace it with the Species Conservation Act, 2025 (SCA), which I believe would substantially weaken the protections currently in place for vulnerable species and their habitats.

A central issue is the shift to a registration-first model, which places the burden entirely on the proponent and eliminates crucial oversight. This kind of unchecked approach jeopardizes responsible development. A permit-based system that includes regulatory review is vital—it ensures accountability and requires developers to actively avoid and protect critical habitats for at-risk species in Ontario.

Allowing the government to selectively choose which species assessed by COSSARO receive legal protection removes objectivity from a process that must remain firmly rooted in science. Such discretion opens the door to political influence in decisions that should be informed solely by ecological evidence.

While I recognize that the current habitat definitions may be unclear for some species, narrowing these definitions could result in the exclusion of essential areas needed for species to survive. Instead, the province should invest in scientifically grounded, species-specific definitions that balance habitat protection with the need for infrastructure development.

Additionally, removing the requirement for recovery strategies and providing no framework to assess a species’ recovery over time undermines the purpose of conservation legislation. This would be a significant setback. Rather, the government should prioritize research to fill existing knowledge gaps and generate reliable data—data that can guide the identification of critical habitats and support effective, targeted recovery actions.

The responsibility for managing natural resources—and by extension, habitats for species at risk—falls to the province. It is essential that Ontario continues to develop regionally tailored conservation strategies that reflect the diversity of its landscapes. The elimination of formal advisory committees further limits opportunities for collaboration and diminishes the province’s capacity to engage with conservation experts and organizations.

I strongly urge the government to uphold automatic legal protection for all species classified by COSSARO as extirpated, endangered, or threatened. Scientific evidence—not discretion—must remain the foundation of these decisions. Oversight through a permitting system should remain in place for activities that carry medium to high risks to species or their habitats. The definition of habitat should be broadened to encompass all aspects of a species’ ecological needs, including foraging grounds, dispersal corridors, and seasonal use areas. It’s also critical to maintain a legislated recovery planning framework to provide a coherent strategy for species recovery. Finally, transparent and dedicated funding, along with mechanisms for expert and stakeholder input, must be preserved to enable meaningful conservation efforts.

Streamlining processes should not come at the expense of species protection. I urge the government to ensure that any new legislation is guided by science, grounded in transparency, and demonstrates a firm commitment to safeguarding Ontario’s biodiversity.