I’m replying to the…

I’m replying to the government’s request for public comment on their proposal to introduce Bill 5.

My brief statement is to express my opposition to this proposal. I have several reasons for my stance.

The government states that the purpose of the amendment is to emphasize species protection and conservation while considering social and economic factors for sustainable growth.

In my view, their primary purpose is to promote business and economic interests for sustainable growth. The government is not primarily interested in protecting species, as evidenced by their move to eliminate recovery products for species. They seek flexibility in this shift for business reasons, not for environmental and species protection.

The government is taking almost complete control to fit their business agenda, even removing the ability to establish an advisory committee. They will consult and seek advice only if they feel it is necessary.

COSSARO will continue to identify and create lists of endangered species, but it will not have any advisory or enforcement authority. The government will have the discretion to remove protected species from their scientifically established lists, potentially making it easier for business proposals to sidestep regulations.

They are shifting nearly all species-related authorizations to a registration-first approach. This allows proponents to register their proposals and begin work immediately, with the only provision being that they comply with existing regulations. A lot of damage to habitats can occur before their proposals are granted permission. This is unacceptable.

At this point, the government has not established the regulations. In my opinion, these must be set up first before the registration process begins. Proponents must know all the regulations before they register their proposals. The ministry plans to develop these regulations in consultation with the public and Indigenous communities over the coming months.

The Ontario government is trying to reduce duplication with federal legislation. Proponents will be able to initiate their proposals on non-federal land without seeking approval from federal legislation. This must not happen. Migratory birds and fish will use both provincial and federal land, and proponents must comply with the regulations in both jurisdictions before any proposal is initiated.

This proposed legislation reflects a move toward more authoritarian governance. As well, it opens the door to more cronyism.

In this context, I see this government as wanting to adopt a more authoritarian position regarding the approval of business ventures. They seek full control of decision-making and do not allow for an arms-length or independent assessment agency to address environmental problems that may arise. In this proposed amendment, they do not mention anything about penalties or consequences for inappropriate proposals that hastily got underway before being appropriately assessed.

A healthy environment for all species supports a healthy society. Business does not come first. Bill 5 puts business first and gives the government full control to make this happen. Bill 5 must not go through.