Comment
Our volunteer nonpartisan organization active in our riding, is very concerned about the proposed changes to The Endangered Species Act in Schedule 2 of Bill 5. If these proposed changes are enacted, species at risk in Ontario will no longer be protected. We request Schedule 2 of Bill 5 be withdrawn.
Justina Ray, a scientist with The Wildlife Conservation Society of Canada, tells us Ontario has one third of Canada’s surface freshwater and globally significant species biodiversity. One quarter of all species in Canada are in Ontario. Of hemispheric importance, Ontario is a crucial passageway and stopover for migratory birds. There are 230 species at risk in Ontario, mostly due to habitant loss from urban sprawl and development. Further, we are told the north and far north peat bogs provide significant carbon storage which development will disturb resulting in carbon emissions dangerous to managing climate change.
We have reviewed the submission of the Canadian Environmental Law Association, CELA, dated May 2025 with respect to this proposed legislation, and we agree with and support its findings, concerns and recommendations.
Bill 5 Schedule 2 indicates this government either does not show an understanding of the science of species at risk, nor an appreciation of the need to preserve, protect and recover species at risk as a result of human interference, or doesn’t care that biodiversity and the protection of endangered species is worth protecting. This legislation clearly proposes to balance protecting species at risk with socio-economic considerations. There is no place for a balancing act if species protection is appreciated and provided in provincial law. Extinction is forever. If the government causes species at risk to fail in order to fast forward development, this will benefit the few to the detriment of us all.
We draw attention to the following points of the CELA submission, which are also found in the submissions of other organizations and individuals.
The narrow definition of habitat does not include where animal species live, breed, feed, and mature, nor anything beyond the roots of plant species. Restricting protection to these finite areas narrows the scope which will result in further failure of our government to protect species already at risk of extinction. Further, removing harassment from prohibited actions allows construction noise, disruption and its ongoing effects to continue to harm threatened animals and plants.
Can we realistically expect the prohibition of actions or engaging in action that protects species at risk to be voluntary? Can we expect advisory committees made up of industry stakeholders whose interests are development, not protection, to give science based advice? Applications to harm species at risk granted without review, with no inspections to ensure compliance, and few performance measures will not protect species at risk.
The listing of species at risk by COSSARO should not be interfered with by Cabinet, which could do so for political, not scientific reasons. Further, there should not be delegation of ministry powers to Ministry employees.
Recovery strategies for species at risk are necessary and to remove them and management plans is also unacceptable. The proposed applications focus on individual projects and activities that happen in isolation, without reference to the big picture awareness or planning.
Bill 5 Schedule 2 represents an unacceptable rollback of Ontario’s current framework for protecting species at risk and their habitats. Accordingly we request the withdrawal of Schedule 2 Bill 5.
Submitted May 16, 2025 11:46 AM
Comment on
Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025
ERO number
025-0380
Comment ID
145243
Commenting on behalf of
Comment status