Proposed interim changes to…

Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025 (ERO number 025-0380)

I formally express my objection to Bill 5, specifically Schedules 2 and 10, which propose significant changes to the protection of endangered species and their habitats in Ontario.

The proposed repeal of the Endangered Species Act, 2007, and the introduction of the Species Conservation Act, 2025, would effectively dismantle the existing framework that provides critical protections for endangered, threatened, and special concern species. This change is alarming for several reasons:

1. Reduction of Habitat Protection:
The new definition of “habitat” under the Species Conservation Act, 2025, is severely limited, focussing only on the immediate dwelling places of endangered animals and the root zones of endangered plants. This narrow focus fails to consider the larger ecosystems necessary for the survival of these species, ultimately threatening their existence.

2. Inadequate Measures Against Habitat Destruction:
Unlike the Endangered Species Act, which prohibits activities that could harm habitats, the proposed legislation allows for habitat destruction as long as it is registered. This shift places endangered species at greater risk, as it permits landowners to destroy habitats without meaningful oversight or accountability.

3. Arbitrary Recognition of Species:
The decision-making process regarding the status of species at risk would shift from an independent committee to a political one, allowing for arbitrary determinations that could deny critical protections to species in need.

4. Neglect of Species Recovery Efforts:
Bill 5 explicitly abandons efforts to recover endangered and threatened species, which is a regressive step that undermines previous conservation efforts.

5. Economic Development vs. Biodiversity:
The argument that protecting species and habitats hinders economic growth is unfounded. Historical examples, such as the construction of the Georgian Bay section of Highway 400, demonstrate that it is possible to balance ecological protection with economic development through innovative solutions.

In light of these concerns, I urge you to reconsider the implications of Schedules 2 and 10 of Bill 5. These proposals not only threaten the biodiversity of Ontario but also undermine the rule of law and the integrity of our environmental protections.

Thank you for considering this objection. I hope for a thoughtful review of the potential consequences of this legislation on Ontario's natural heritage.