Subject: Bill 5, the Protect…

Subject: Bill 5, the Protect Ontario by Unleashing our Economy Act, 2025, proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025
Submitted to: Standing Committee on the Interior
Date: 2025-05-14

Dear members of the Standing Committee on the Interior,

I am writing to comment on the proposed Bill 5, Protect Ontario by Unleashing our Economy Act, 2025. This Bill includes proposed interim changes to the Endangered Species Act, 2007, followed by its eventual repeal and the enactment of the Species Conservation Act, 2025. Introduced by Premier Doug Ford and the Progressive Conservative Government of Ontario on April 17, 2025, it is now open for public comments. As a young adult and citizen living in Ontario, attending a post-secondary institution for environmental studies, I feel obligated to voice my concerns about the Bill.

I respectfully submit the following comments for your consideration:

1. The most glaring problem is the changes to the definition of various protections. More specifically, the redefinition of habitat will have repercussions. For animal species, the definition of a habitat is proposed to be narrowed to a dwelling place occupied habitually by one or more species members (Ministry of the Environment, Conservation and Parks, 2025). The justification for this is that the current definition, the area a species relies on for living, gathering food and reproducing, is too broad (Singh, 2025; Ministry of the Environment, Conservation and Parks, 2025). However, the proposed definition is too specific, disregarding key aspects of an animal's survival. It is unfair and unrealistic to expect an animal to survive only in their place of habitation and the immediate land around it. Not to mention, this assumes all animals act the same, which is not true. This redefinition practically guarantees the death of affected animals and, in some cases, extinction (Singh, 2025). I agree that a broad definition creates uncertainty, but a hyper-specific one creates further loopholes.
2. Another issue is the removal of some species from protected status. Under the new law, particular aquatic species and migratory birds currently protected under the Species at Risk Act would be removed, citing protection under federal law as justification (Singh, 2025). Although presented as a time-saving measure, this change fails to consider that federal law was never intended to replace provincial law completely (Singh, 2025). Although they have the power to do so, the federal government rarely acts on their authority over invasive species. Hence, removing aquatic and migratory birds creates a possible loophole (Singh, 2025).
3. Changes to how permits are submitted, from permits to online applications, would allow developers to start their projects immediately following registration under their discretion (Bowman, 2025). This shifts the process to having no time for problems to be identified with applications, for an environmental assessment, or for discussing alternative methods. It is clear that the Bill aims to prioritize developments over the integrity of Ontario's diverse ecosystems, and I cannot support that as an informed citizen.
4. With changes in authority, there is more potential for mismanagement. The Bill would allow the government to remove a species from the protected list, a responsibility historically solely assigned to the Committee on the Status of Species at Risk in Ontario (COSSARO) (Norris & Webber, 2025). The Bill proposes that the government have the power to add and remove species at their discretion, completely undermining the role of COSSARO and the value an independent body should have (Ministry of the Environment, Conservation and Parks, 2025; Norris & Webber, 2025). This is an apparent conflict of interest.
5. The next set of issues relates to the political perceptions of the Bill. First, the implications of the Special Economic Zones Act would grant unlawful power to create law-free zones where municipal and provincial laws do not apply (Bowman, 2025). This can be applied to any project, meaning that currently protected sites can be stripped of their status and destroyed (Bowman, 2025). This is a gross abuse of power. Under no circumstances should a governing body be able to pick and choose when laws apply. Furthermore, this undermines the democratic process as a whole.

In response to these issues, I encourage the committee to consider the following recommendations:

1. Consider investing in already developed land in southern Ontario. Condominiums, for example, hold more people per area than any other type of housing. They also come with benefits like the rationale for investing in public transport, the possibility of more public parks, and preserved ecosystems for all to enjoy.
2. Amend Bill 5. Under no circumstances should any government be given the power to overrule a recognized independent body’s decisions. Additionally, consider removing the Special Economic Zones Act, which is undemocratic.
3. Seek inter-governmental agreements on definitions, classification and management of species at risk to avoid jurisdictional loopholes. Ensure that necessary legislation is in place at the federal level if removing species from protection under Provincial law.
4. Introduce a mandatory review period following proponent submissions into the new online registration system. Consider using artificial intelligence to flag target words for individuals to review manually. Ideally, retain the current system.
5. Adopt a science-based classification of habitat that is recognized federally. Introduce different requirements/ regulations for developments around core, buffer and migratory zones around a habitat. In the case of endangered species, prohibit any developments that risk disturbance.

Therefore, Ontario's economy and environment are not mutually exclusive. We can pursue economic prosperity without compromising the environment, rights, and democratic processes that define this province and its people. It is not the endangered species or their habitat causing economic difficulties in Ontario, nor are loopholes the key to financial success. On this note, I want to remind the reader that Ontario's natural beauty is a finite resource, and the precedent the enactment of Bill 5 will set threatens the integrity of Canada as a global environmental leader. We cannot let this happen.

Thank you for the opportunity to provide input on this legislation.

Sincerely,

A concerned citizen