The Hamilton Naturalists’…

The Hamilton Naturalists’ Club (HNC) is submitting the following comments about the proposed Protect Ontario by Unleashing Our Economy Act, 2025. HNC has several concerns with the Bill and urges the provincial government to withdraw it. We are concerned that the proposed legislation will dismantle or undermine many key legal protections that safeguard our environment, human health, and Indigenous rights. HNC is a 106 year old conservation charity with almost 400 members dedicated to the study, appreciation, and conservation of our wild plants and animals.

The proposed legislation will reduce safeguards for endangered species at a time when we’re facing a biodiversity crisis.. Ontario’s Endangered Species Act was once considered strong legislation for endangered species protection but those protections have declined over time. Ontario had 22% more species at risk in 2020 compared to 2009. The ESA is one of the few tools available to protect at-risk wildlife and the ecosystems they depend on. Replacing it with vague “goals” and unenforceable measures will lead to the further decline of species already on the brink. It seems like this deregulation is putting short-term industrial gain ahead of long-term ecological and community health. 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

The proposed change to the definition of habitat will reduced it to just “a den, nest or other similar place that is occupied…” This is in contrast to the Endangered Species Act which defines habitat much more broadly as, “an area on which the species depends, directly or indirectly, to carry on its life processes, including life processes such as reproduction, rearing, hibernation, migration or feeding.” It also removes the requirement for the government to develop a recovery strategy, management plan, response statement and review of progress. These are critically important documents that guide the protection and recovery of endangered species. In addition, offloading responsibility for migratory birds and aquatic species to the federal government is an unprecedented abrogation of provincial responsibility and negates the essential collaboration between both levels of government.

HNC is alarmed by the proposal to create “special economic zones” that would allow cabinet to approve major development projects without proper environmental assessment, public input or Indigenous consultation. This massive short cut to the permitting process undermines transparency, accountability and Ontario’s duty to uphold Indigenous rights and treaties.

Fast-track mining and infrastructure development — including in ecologically sensitive and contested areas like the Ring of Fire — without proper consultation or consent from Indigenous communities is very concerning. 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.

HNC is concerned that the proposed legislation in a large omnibus bill will weaken Ontarians say in decisions that affect the province’s land, water and future. This is a time when we should be working together to care for Ontario’s important species and spaces.

Hamilton Naturalists’ Club urges 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.

Please remember that healthy habitats sustain all Ontarians, not just endangered species. Bulldozing their protections is only going to unleash more problems for future generations in the long run.