The proposed changes to…

ERO number

025-0380

Comment ID

145575

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed changes to Ontario’s Endangered Species Act under Bill 5 significantly weaken the legal framework essential for protecting at-risk species. Strong, enforceable laws are critical to holding individuals and industries accountable and ensuring species recovery through science-based planning and habitat protection.

Key concerns include:
• Increased political discretion over species listing, undermining COSSARO’s independent science-based assessments, reducing scientific integrity and accountability.
• Removal of mandatory recovery strategies, undermining long-term conservation planning.
• “Registration-first” development model, allowing harmful activities without prior review.
• Disbanding of expert bodies like the Species Conservation Action Agency, reducing oversight and technical expertise.
• Lack of guaranteed Indigenous consultation, raising serious equity and rights concerns.
• Creation of “special economic zones”, that could override environmental protections entirely.
• A narrowed definition of habitat that excludes vital areas like migration corridors and foraging grounds.

Ontario should instead strengthen the ESA by maintaining a broad habitat definition, reinstating mandatory recovery plans, ensuring science-led species listing, investing in enforcement, and upholding Indigenous rights.

To protect Ontario’s species at risk, Bill 5 must be revised to reflect science, accountability, and long-term conservation. Key recommendations:
• Habitat Protection: Keep the broad, science-based definition of habitat.
• Species Listing: Make COSSARO’s assessments legally binding, free from political interference.
• Recovery Planning: Restore mandatory, well-funded recovery strategies with clear targets and timelines.
• Permitting: Maintain strong permitting and environmental assessments; limit the “registration-first” model.
• Oversight Bodies: Retain expert advisory groups to ensure transparency and collaboration.
• Full Species Coverage: Guarantee protection for all species, including federally protected migratory and aquatic species.
• Funding: Provide dedicated, long-term funding for recovery and stewardship.
• Enforcement: Strengthen enforcement capacity and penalties for non-compliance.
• Indigenous Consultation: Ensure early, meaningful consultation with Indigenous communities.
• Special Economic Zones: Eliminate exemptions that could override environmental laws.

Conclusion:
Ontario’s Endangered Species Act must be a pillar of ecological responsibility, not weakened in favor of short-term economic interests. The proposed changes threaten biodiversity and ignore scientific and public concern. The province should strengthen—not dismantle—its commitment to species protection for the sake of future generations and a thriving natural environment.