Comment
Our organization of 170 members opposes Bill 5’s attempt to undermine the Endangered Species Act. Bill 5 is a vehicle which threatens to roll back key protections for species at risk and habitats on which they depend. If passed, it will weaken the very laws that prevent species from facing extinction. From drastically weakening permitting processes and definitions of what harms a species, to redefining what a species habitat is, there are huge implications for Ontario’s wildlife. The proposed actions are not science-based.
More specifically, the following issues are of genuine concern:
Redefining “habitat” to just immediate dwellings like dens, nesting sites, or the
critical root zone will remove protections from large areas of habitat upon which
species depend for their survival;
ii. The discretionary listing of species removes an essential independent and
science-based assessment process;
iii. Offloading responsibility for migratory birds and aquatic species to the federal
government negates the essential collaboration between both levels of
government and combined with the weakened definition of habitat in the
provincial proposal limits protection for species that are only listed provincially;
iv. Allowing developers or industry to simply register and then operate without clear
conditions or binding requirements removes the province's ability to ensure
sustainable operations and avoid adverse impact on endangered species;
v. Eliminating recovery strategies makes it nearly impossible to assess, mitigate
and avoid harms to species; and
vi. The text and preamble of the Species Conservation Act (SCA) creates an
impression that it is purely performative and is not intended to prevent the
ongoing decline of endangered species in practice.
Recommendations
Indigenous Peoples’ right to free, prior and informed consent (FPIC) is not mentioned
anywhere in this proposal. FPIC must be the bedrock of any decisions, policies or
legislation impacting the territories of Indigenous Peoples.
We urge you to halt this proposal and instead strengthen the ESA so that species can
flourish, communities can benefit from conservation and Indigenous rights are
respected. Many provinces across the country are showing how this can be done.
That doesn’t mean stopping all development. It means building strong local economies
that are in harmony with nature, not in conflict.
In conclusion we urge your government to remember that healthy habitats sustain all
Ontarians, not just endangered species. Caring for habitats and maintaining healthy ecosystems can provide future generations with the natural resources and beautiful surroundings that are necessary for healthy happy living.
Submitted May 17, 2025 5:49 PM
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
148150
Commenting on behalf of
Comment status