I am writing to express my…

I am writing to express my strong opposition to Bill 5. Although I recognize the need for accessible and affordable housing, I do not believe this Bill adequately addresses this issue and will worsen the ongoing biodiversity crisis in Ontario. For context, I am a research biologist currently working with conservation programs in Ontario, with 8 years of experience in ecology, evolution, and conservation research.
I have 4 main concerns with this bill:
1. Changing the definition of habitat to “a dwelling-place, such as a den, nest or other similar place, that is occupied or habitually occupied by one or more members of a species for the purposes of breeding, rearing, staging, wintering or hibernating, and the area immediately around a dwelling place described in subclause (i) that is essential for the purposes set out in that subclause.”

This definition is unscientific and has no basis in biological reality. Animals require sufficient space containing appropriate habitat to find food, water, mates, choose a suitable site for reproduction, evade predators, find shelter, etc. This definition of habitat includes only a tiny sliver of the space an animal requires to survive, and will result in next to no actual protection for any species. What happens in the case where an animal is seen on a site, but the burrow/den/nest is not seen? This change is nonsensical and damaging, particularly considering that habitat loss is the greatest threat to species at risk, threatening >80% of threatened species in Canada (Venter et al. 2006) and globally (Hogue & Breon 2022). To properly address the biodiversity crisis and facilitate species recovery we need to increase habitat availability and connectivity, not further destroy and fragment habitat - which is what this Bill will do with its updated definition of “habitat”.

2. Lack of clarity about the process through which “special economic zones” and registered activities/proponents will be designated. The Bill merely states that actives are prohibited unless “the person has registered the activity in the Registry in accordance with the regulations”. What are the regulations? Who will be consulted to develop these regulations? Will Indigenous and local communities have the final say on activities that happen under their jurisdiction? With insufficient regulations, development will be allowed to begin without a proper environmental assessment under this Bill, which will have devastating impacts on local biodiversity.

3. This Bill is being pushed under the guise of increasing development of much-needed transit, housing, health and long-term care, and other infrastructure. As laid out in the Bill, if a project “could potentially advance one or more of …[these]… provincial priorities” , the project may be exempt from meeting requirements of the Environmental Bill of Rights. Removing protections for endangered species and protected habitat will not adequately address the transit and housing needs in Ontario. A focus on building houses in areas that are already developed, changing zoning laws to increase density, and investing in affordable and government-subsidized housing are effective ways to address the housing crisis without furthering the biodiversity crisis we are in.

4. The government claims that this Bill will improve conservation actions by investing “$20 million annually to fund projects that support real, measurable outcomes”. I am absolutely in support of increasing spending for conservation mitigation actions, as I see incredible, on-the-ground conservation organizations continually struggling to find adequate funding for their programs. However, this Bill will drastically increase environmental destruction and the need for mitigation efforts. Investing in solutions while actively increasing the problem is an incredibly inefficient way to approach species conservation. The government should be strengthening the Endangered Species Act and investing in improving and increasing habitat quality, rather than actively causing further destruction, and claiming to be investing in conservation by throwing money at the problems they will be causing.