I am writing to you in…

I am writing to you in response to the recently introduced Bill 5, Protecting Ontario by Unleashing our Economy Act, 2025. As a concerned citizen with a degree in environmental science and having published my thesis on the topic of evidence-based prioritization for species conservation, I am calling on you to withdraw this regressive and harmful bill that will speed up the destruction of critical habitat for endangered species, removes basic environmental rights. It interferes with our rights to be informed and have a say, threatens our rights to a healthy environment, as recognized by the Canadian EPA, and also fails to respect Indigenous peoples' rights, including those recognized in the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP).

Impacts on Biodiversity and species conservation:
Far from helping to protect Ontario, the new law offered to replace the Endangered Species Act of Ontario, the so-called “Species Conservation Act, 2025” would, if enacted in anything like its current form, do the exact opposite of its stated intent. It would effectively end protection for species at risk in Ontario, threatening species survival and recovery.
I support efficiencies, robust environmental laws, transparency, and holding proponents to account to the highest standards (not giving them free rein).

Here are several of the problems I see with the new proposed Act:
-It redefines habitat to narrowly cover areas like dens and nests
-it allows irreversible, destructive activities to go ahead as long as they are registered, essentially relying on voluntary initiatives
-it makes the adding and removing of species protection discretionary, and undermines the independent, science-based nature of COSSARO
-it inserts economics into the new purpose and protection and recovery objectives are out.
-it isn’t set up to protect and recover species;
-it eschews science;

The new proposed law is clearly designed to strip protection altogether from almost all of the critical habitat protected by the Endangered Species Act, 2007, reducing the definition of “habitat” to tiny slivers of land—the immediate “dwelling place” of an endangered animal (such as around dens or nests) and the immediate “root zone” of an endangered plant. If adopted, this change would doom endangered and threatened species to extinction. Protecting the den of an endangered animal won’t keep it alive if the larger grasslands, forests or wetlands it depends on for food are paved for sprawl.
In addition removing “harass” from the prohibitions regarding harms to species will also drastically remove species protection, and cause confusion/conflict with the protections that must be respected for migratory birds and aquatic species under the federal Species at Risk Act.

Removal of permitting process, proponents should NOT be able to start work as soon as they are registered. This essentially removes the approval process entirely and incentivizes submission of projects with known impacts on wildlife, because investigation into the impacts will not happen, or the impacts of the proposed projects only known after the work has already been completed.
This government has an abysmal track record. In 2021, Ontario’s auditor general “Value-for-Money Audit: Protecting and Recovering Species at Risk” reviewed the province’s efforts to protect species at risk under the Endangered Species Act, releasing a critical and bleak evaluation. It found the province had never denied an application to harm an at-risk species or its habitat, nor inspected these activities it authorized to ensure they were in compliance.

The “general prohibition for activities that would result in a species no longer living in the wild in Ontario” is a sneaky way of saying that they will only protect the last individual of a given threatened species, and will do nothing/be too late to protect that species from extinction, compared to safeguarding a viable population.

The province’s regressive approach to species protection adds to a history of vast and sweeping amendments from other prior and passed bills that have exempted major extractive industries from the ESA’s protective measures, delayed the classification of species on the Species At Risk in Ontario (SARO) List, broadened Ministerial decision-making powers absent a requirement to seek expert advice, and limited the publicly accessible and transparent information sharing.

Wind Down of the Species Conservation Action Agency:
In 2021, your government created the “pay to destroy” Species Conservation Action Agency (SCAA), stating “Protecting species at risk and providing strong environmental oversight is a top priority for Ontario” (https://www.pas.gov.on.ca/Home/Agency/674). This is obviously false, and the collected dedicated funds that have not resulted in any projects. You have built a faulty system, a shell-game that has failed to carry out its purpose. It would be much more effective for your government to stop "fixing what wasn't broken" by not breaking it in the first place.

Recovery Plans and Documents:
“The proposed amendments to the ESA would remove the requirements to develop recovery strategies and management plans, government response statements, and reviews of progress from legislation” is not congruent with a commitment to provide “information and guidance on the conservation of species in Ontario”, and indeed does not result in “ focusing resources in a way that would maximize benefits for species”. Removing recovery strategies and management plans is the antithesis of maximizing benefits, making it nearly impossible to track and mitigate threats to their survival. In addition, removing reviews of progress is removing government accountability for the Species Conservation Act to actually support any species conservation.

This bill is framed as a special tool to fast-track projects that help protect Ontario, the language used is intentionally vague and provides nothing to identify or promote interests for Ontarians. The health and sustainability of Ontario’s economy is dependent on the functioning and sustainability of Ontario’s ecosystems – This bill says it will unleash the economy, however, in reality the wanton and short-sighted destruction of Ontario’s ecosystems will have long-term consequences on the sustainability and longevity of ALL economic activities that depend on natural resources. The short-term economic benefits will not end up in the hands of hard-working Ontarians, but instead be funneled into few private interests, namely mining proponents and development projects, at the cost of any legal requirement to consider the interests of the public, communities, nature and health. The current Ontario government has already shown that it cannot be trusted to prevent corruption from eroding our public goods (See Greenbelt scandal). If passed, Bill 5 will undoubtedly erode public confidence in transparent and accountable government decision-making and cause irreparable harm to environmental and human rights. The reality is that our economy is embedded in nature – a fact recognized at local and global levels (GLOBAL BIODIVERSITY FRAMEWORK).

McCune: 80% of Canadians (40% of surveys in Ontario) are strongly committed to species conservation in principle (89% agree), including the need to limit industrial development (80% agree).
McCune JL, Carlsson AM, Colla S, Davy C, Favaro B, Ford AT, Fraser KC, and Martins EG. 2017. Assessing public commitment to endangered species protection: A Canadian case study. FACETS 2:178-194.

In summary Bill 5 will effectively end provincial protection for species at risk and the critical ecosystem services that help Ontario thrive.