Comment from IFAW Canada re:…

Comment from IFAW Canada re: “Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025”. ERO Number 025-0380.

On behalf of the International Fund for Animal Welfare and our Ontario supporters, we wish to submit the following comments regarding the Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025, ERO Number 025-0380.

We commend the government of Ontario’s commitment to increase financial investment in activities that will assist the protection and conservation of species. However, we remain deeply concerned by certain aspects of Bill 5 and its proposed amendments to Ontario’s Endangered Species Act. These changes significantly weaken protections for some of our province’s most vulnerable plants and animals, and they prioritize short-term development interests over long-term environmental responsibility.

Specifically, we would like to express our concern about the following provisions:
1. Creation of “Special Economic Zones” allows developers to circumvent environmental legislation entirely, with no regard to damage to the environment or duty to consult. No project should be exempt from the law
2. The “registration-first” approach that allows immediate development, with any public and Indigenous consultation occurring later. This approach allows irreversible damage to occur and does not respect Indigenous rights to free prior and informed consent.
3. Ministerial discretion – Granting Cabinet the power to determine which plants and animals are designated for protection, override scientific recommendations, and delay recovery strategies removes transparency and undermines the role of scientific experts and independent oversight in conservation decisions. Environmental protection and decisions that affect Ontario’s biodiversity should be evidence-based, not politically driven.
4. Redefined and weakened protections for species at risk and habitat – By removing harassment form the list of activities requiring a permit, and narrowly redefining “habitat” to include only a species’ den or nest and the immediate space around it, Bill 5 ignores common sense, which tells us that animals move around, and that ongoing and pervasive harassment can impact a species ability to survive and reproduce.

Protecting biodiversity, human health, and the economy go hand in hand. Economic growth is important, but not if it is achieved at the expense of Ontario’s biodiversity and natural resources. . Healthy ecosystems are the backbone of a healthy economy, and healthy Ontario communities. To build a strong Ontario, we need a strong Endangered Species Act that protects biodiversity and ensures Ontarians can continue to benefit from the many ecosystem services that nature provides, such as clean drinking water, climate change mitigation, and carbon capture.

While there is undoubtedly red-tape in the provincial government that needs to be removed, allowing environmental deregulation with no accountability at the expense of biodiversity loss is not the solution. Ontario needs strong leadership and strategic economic development to develop economic self-sufficiency and resilience. However, there is zero evidence that any aspect of the current economic crisis is being caused by projects held up by the Endangered Species Act. The desire for economic growth should not be used as an excuse to reduce or dismantle biodiversity protections, nor does it eliminate the need for prudent and strategic planning and oversight

Ontario’s wildlife, ecosystems, and future generations deserve strong, science-based environmental laws. Our environment is not a resource to be exploited at the expense of future generations – it is a responsibility we must protect, and long-term environmental stewardship should be prioritized over short-term economic interests. Protecting endangered species is not optional – it is a moral and ecological necessity.