I strongly oppose the…

I strongly oppose the proposed Bill 5, Protect Ontario by Unleashing Our Economy Act, 2025.

If approved, this legislation would reduce protection for species at risk, increase the loss of habitat for imperiled species, and hamper their recovery. Loss of these species and their habitats leads to reduced ecosystem functioning, which in turn has consequences for human health.

The proposed interim changes to the Ontario Endangered Species Act, 2007 and a proposal to repeal the Ontario Endangered Species Act (ESA) and replace it with the Species Conservation Act would further weaken Ontario’s commitment to protecting species and ensuring their recovery.

The Species Conservation Act would greatly reduce habitat protection.

Under the proposed guidelines, habitat for species at risk animals would be redefined as “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.” Without protection of foraging, cover, and movement corridor habitat, wildlife are at risk of further declines or outright loss. Furthermore, with natural succession, climate change related impacts to species and habitat, and human use near wildlife habitat, there is a necessity to ensure appropriate habitat is available for species to move. Permanent losses or fragmentation of habitat that prevent natural movements of wildlife seasonally or over time will accelerate declines and possibly lead to extirpation. The landscape will not look the same a century from now, so consideration for long-term protection of habitat and natural corridors is essential.

All species of turtle in Ontario are listed federally as species at risk, and most are listed provincially. As an example, the Blanding’s Turtle is Threatened in Ontario. Currently, habitat protection for the Blanding’s Turtle under the ESA offers some protection to wetlands up to 2 km from a confirmed location. Such habitat protection recognizes that individual Blanding’s Turtles often make use of multiple wetlands over the course of the year and move extensive distances across the landscape. The proposed new definition of habitat could only protect where the turtle lays her eggs or one small wetland where the turtle overwinters, if that location is known. Confirming the location of overwintering sites of individual turtles is challenging and requires dedicated funding and skilled personnel. The proposed habitat changes would allow the destruction of numerous wetlands that are no longer considered habitat, leading to the eventual loss of an entire population.

The proposed plan would also do away with the requirement to prepare “recovery strategies and management plans, government response statements, and review of progress from legislation.” While there can be some overlap between federal and provincial recovery documents, the threats in Ontario may differ from those faced in other parts of Canada. Doing away with recovery planning documents is like throwing away the map while trying to navigate difficult terrain. These documents provide invaluable guidance for conservation not only in Ontario, but across the entire species range. Ontario is a leader in providing transparent, accessible information on navigating species-at-risk conservation legislation and action; Bill 5 would make us an embarrassment.

The proposed changes would also move from a permitting system to a self-registration system. No longer will proponents need to make mitigation plans to create an overall benefit, now developers can “get projects started as soon as they have completed their online registration”. Such a system will inevitably lead to increased destruction of habitat for species at risk and a disregard for project management that balances both development and wildlife habitat.

The proposed changes also give the government discretion to remove species from the Species at Risk in Ontario List. Species assessment and listing must be carried out using the best available science, and be prepared by taxa specialists. Political control of listing species goes against the core principles of the original legislation, and has no scientific merit. Such actions are dangerous and short-sighted, with a high potential to lead to further declines of species at risk.

The Endangered Species Act was once considered strong legislation for endangered species protection, but has been steadily eroded by successive provincial governments seeking to pander to the special interests of big industry such as developers and forestry. Despite claims of maintaining environmental standards, the proposed legislation undermines them at every turn.

The bill prioritizes speed over scrutiny, eroding decades of hard-won protections in the name of efficiency. THIS IS NOT A ZERO SUM GAME. Species-at-risk protection and housing affordability are achievable in tandem; it is greed and apathy that leads to destruction of species homes for the benefit of ours. Rather than decreasing protections, efforts should be put in place to further increase the strength of the legislation for species at risk. Returning to the original ESA protections from 2007 should be the goal, not the reduction of protections that have occurred already, and those proposed in this bill.

Destruction of wildlife habitat poses critical threats to many species and losing more natural habitat will make species more at risk of being extirpated. Southwestern Ontario in particular is one of the most biologically diverse regions of Canada, though the majority of forests and wetlands have been lost, damaged or fragmented. To allow the destruction of more forests and wetlands will reduce biodiversity and the quality of life for all Ontarians. Building smarter, denser, connected, and walkable cities should be the goal for ensuring healthy human communities and natural areas. Clearing more forests and draining more wetlands will lead to more urban sprawl.

I urge the government of Ontario to reject this proposed bill.