I am writing to express my…

I am writing to express my strong opposition to the proposed changes outlined in ERO Notice 025-0380 and the broader legislative framework of Bill 5. While I acknowledge the importance of streamlining processes to support economic development, the proposed amendments pose significant risks to Ontario’s biodiversity and environmental integrity.

1. Discretionary Species Listing: Granting the government discretion to add or remove species from the protected list, despite assessments by the Committee on the Status of Species at Risk in Ontario (COSSARO), undermines science-based decision-making and could lead to inconsistent protections.
2. Redefinition of “Habitat”: The proposed narrowing of the “habitat” definition may exclude critical areas necessary for species’ survival, thereby weakening habitat protection and potentially accelerating species decline.
3. Shift to Registration-First Approach: Allowing proponents to commence activities immediately after registration, without prior review, increases the risk of harm to species and habitats, as it reduces oversight and the opportunity for mitigation measures.
4. Removal of “Harass” from Protections: Eliminating the term “harass” from species protections could permit activities that disturb species, leading to stress and behavioral changes detrimental to their survival.
5. Potential Conflicts of Interest: The introduction of “Special Economic Zones” and designation of “trusted proponents” could prioritize economic interests over environmental protections, leading to biased decision-making and reduced public trust.

Recommendations:
- Maintain Science-Based Protections: Ensure that species listing and delisting decisions remain grounded in scientific assessments by COSSARO, without political interference.
- Preserve Comprehensive Habitat Definitions: Retain the current, broader definitions of habitat to encompass all areas essential for species’ life processes.
- Implement Rigorous Oversight: Before activities commence, require thorough environmental assessments and approvals to prevent irreversible harm to species and ecosystems.
- Retain Comprehensive Protections: Keep terms like “harass” within species protection language to safeguard against all forms of disturbance.
- Ensure Transparency and Public Involvement: Avoid creating mechanisms that could sideline public input and environmental considerations in favor of expedited economic development.

Ontario’s natural heritage is invaluable, not only for its ecological significance but also for the well-being of its residents. I urge the Ministry to reconsider these proposed changes and prioritize the protection of our province’s biodiversity.