Submission to the…

Submission to the Environmental Registry of Ontario
Re: Opposition to Bill 5 – Protect Ontario by Unleashing our Economy Act, 2025
Submitted by: Concerned Citizens of Ramara, supported by the Rescue Lake Simcoe Coalition.

Date: May 12, 2025
1. Loss of Protection for Endangered Species and Ecosystems
Bill 5 repeals the Endangered Species Act, 2007 and replaces it with the Species
Conservation Act, 2025, which significantly weakens protections for Ontario’s most
vulnerable species. The new legislation:
- Makes species listing discretionary, allowing Cabinet to ignore scientific recommendations
from COSSARO, (Committee on the Status of Species at Risk in Ontario)
- Removes automatic habitat protections and recovery strategies.
- Shifts the purpose of species protection to accommodate economic growth rather than
ecological integrity.
These changes will directly threaten biodiversity across Ontario—including in rural and
agricultural areas where farmland and natural ecosystems intersect.

2. Threats to Farmland and the Ecosystem Services It Provides
Preserving farmland is not only essential for food security and rural livelihoods, but also for
maintaining the ecological functions of soil, water, and biodiversity. Bill 5 undermines
farmland protection by:
- Prioritizing rapid development, mining, and infrastructure in "Special Economic Zones,"
which could override municipal zoning bylaws, including those designed to protect prime
agricultural lands.
- Removing environmental assessment requirements for certain large-scale projects,
increasing the risk of land degradation, water contamination, and habitat fragmentation
near or on farmland.
- Narrowing the definition of “habitat” and reducing oversight, putting farmland-adjacent
ecosystems—such as hedgerows, wetlands, and riparian zones—at risk.
Ontario’s farmland plays a critical role in water filtration, carbon sequestration, and species
habitat. Weakening protections disconnects farming from the essential ecosystems it
supports and relies on.

3. Risks to Water Resources and Aquifers
Bill 5 facilitates the fast-tracking of projects near sensitive areas without requiring proper
environmental assessments. This is of great concern in regions like Ramara Township,
where agricultural lands lie atop highly vulnerable aquifers. Without proper protections,
the risk of nutrient runoff, groundwater contamination, and altered hydrology
increases—compromising drinking water and the health of Lake Simcoe and surrounding
tributaries.

4. Violation of Indigenous Rights
Bill 5 offers no guarantees for free, prior, and informed consent (FPIC) from Indigenous
communities, as outlined in the United Nations Declaration on the Rights of Indigenous
Peoples. By concentrating decision-making authority in Cabinet and enabling broad
regulatory exemptions under the Special Economic Zones Act, the legislation undermines
Indigenous jurisdiction, cultural heritage, and treaty obligations.
Further, amendments to the Ontario Heritage Act weaken archaeological protections,
allowing development to proceed without adequate investigation of sacred or culturally
significant sites.

Conclusion and Request
We urge the Government of Ontario to repeal Bill 5 in its entirety and commit to:
- Upholding science-based protections for endangered species and their habitats.
- Protecting farmland as a vital ecological and economic resource.
- Safeguarding our water systems through robust, transparent environmental assessment.
- Respecting Indigenous rights to free, prior, and informed consent in all land-use decisions.
The future of Ontario’s environmental health, food systems, and democratic planning
processes depend on rejecting this regressive legislation.

Addendum: Supporting Public Concerns and Expanded Context
Public concern regarding Bill 5 is widespread and well-founded. Numerous organizations,
environmental experts, and Indigenous leaders have raised alarms about the irreversible
damage this legislation could cause to Ontario's ecosystems, species at risk, water systems,
and Indigenous sovereignty.
As Water Watchers and others have noted, the claim that Bill 5 is an economic defense
mechanism is misleading. This bill borrows tactics seen in anti-environmental governance,
removing oversight under the pretense of economic necessity. Habitat protections have
been gutted to only cover nests, dens, and critical root zones, ignoring the broader
ecological context animals and plants need to survive — such as migratory paths, riparian
corridors, and runoff-fed nutrient systems.
The Species Conservation Act allows for self-registration of potentially harmful activities,
replacing prior permitting and public accountability. This opens the door to unchecked
degradation of essential habitats.
Special Economic Zones established under Bill 5 threaten not only local governance but also
Indigenous sovereignty. Indigenous Nations, particularly those in northern Ontario near the
Ring of Fire, face decisions made without consultation or consent. This directly violates
Canada's obligations under the United Nations Declaration on the Rights of Indigenous
Peoples (UNDRIP).
Multiple endangered species — including the Cerulean Warbler, Monarch Butterfly, and
Loggerhead Shrike — already face existential threats from habitat loss. Removing
protections now will accelerate biodiversity collapse and contradict Ontario’s obligations
under the Kunming-Montreal Global Biodiversity Framework.
Environmental Defense, Ontario Nature, and the David Suzuki Foundation have each
emphasized that healthy ecosystems are not a barrier to economic development. Instead,
they are its foundation. We echo their call: Ontario must cancel Bill 5, restore the
Endangered Species Act, and commit to environmentally responsible development that
upholds democratic, ecological, and treaty rights.
In conclusion, the Government must listen to its citizens, scientists, Indigenous leaders, and
conservationists and reject this bill. Short-term economic gains cannot outweigh the long-
term health of our water, land, biodiversity, and social justice commitments.