Ontario refuses to study cumulative impacts of development on its most vulnerable species; Pointer investigation reveals widespread harm
Graphic by Joel Wittnebel/The Pointer

Ontario refuses to study cumulative impacts of development on its most vulnerable species; Pointer investigation reveals widespread harm

Fading Away is an ongoing series from The Pointer analyzing how government decision making, and its ongoing disregard for environmental stewardship, is impacting Ontario’s most at-risk wildlife. Part 1 can be found here


Before Auditor General Bonnie Lysyk was exposing the inner workings of the PC government’s insidious break-up of the Greenbelt, which she did in spectacular fashion earlier this month, she had already pointedly analyzed just how bad the current government’s track record is when it comes to environmental stewardship and protecting those species most at risk of disappearing from the planet forever. 

In an audit made public in November 2021, Lysyk analyzed the Ontario government’s effectiveness at protecting and recovering species at risk since provincial legislation designed to do so came into force in 2008. Her report was a blistering indictment on the PC government’s utter failure to protect species at risk, and how the ministry responsible for ensuring endangered wildlife receive the protections they are entitled to by provincial law, was actually working opposite to its mandate and actively harming species at risk. 

“The Ministry is essentially facilitating development rather than protecting species at risk,” Lysyk said at the time. 

Many of the same themes that have gripped the public as a result of her investigation into the shady dealings around the parceling out of 15 pieces of land from the Greenbelt—a disregard for the environmental harm; the shunning of the democratic rights of the public; and government systems infiltrated and controlled by private interests—were also identified within Lysyk’s audit of the species at risk file.

Rarely mentioned within the narrative currently unspooling around the Greenbelt scandal—which has mostly focused on calls for Minister of Municipal Affairs and Housing Steve Clark to resign; repeated calls for further investigation into the PCs decision making, or the potential RCMP investigation—is the true impact this ongoing disregard for the environment will have on Ontario’s ability to maintain its biodiversity, something critical to the preservation of cherished greenspaces, the fight against climate change, and human health. 

It’s clear environmental protection is not on Premier Doug Ford’s priority list, evident from his acknowledgement that in the case of the Greenbelt scandal and the flawed process that handed over $8.3 billion in land value to wealthy developers, that the ends justify the means. It’s a startling admission from an Ontario premier who is essentially admitting that flawed and undemocratic processes that cause significant harm to the environment are okay as long as housing gets constructed. 

For years, repeated reports from Ontario’s top environmental experts have warned the incessant push for urbanization that has gripped much of the Greater Toronto Area for the better part of the last 50 years—something Premier Ford and his government have turned into a manic state under the guise of solving the affordability crisis—will have dire impacts for Ontario’s most at risk wildlife. These experts have repeatedly called for the government to study the widespread harm ongoing development across the province is doing to those species on the brink of extinction. And for close to two decades, successive governments have chosen to ignore them. 

“Viewed individually, projects may not be perceived as posing a substantial risk to a species; however, if multiple projects affect a particular species, or occur in close proximity to a sensitive area, they could collectively have catastrophic results, such as jeopardizing the survival of a species,” reads an auditor general’s report from 2013. Similar recommendations to closely study these collective impacts on at-risk wildlife as a result of urbanization can be found as far back as 2009 in reports from the Environmental Commissioner of Ontario. Ford abolished the Environmental Commissioner’s Office in 2019. 

Under the PC government and Premier Ford, the impacts of repeatedly turning a blind eye to the cumulative harm caused to the natural world by development in Ontario are becoming clear. 

An investigation by The Pointer analyzed 43 major development applications across Southern Ontario, including the 15 parcels of land slated for removal from the Greenbelt.  Using primary source environmental impact assessments and data from the Province's own Natural Heritage Information Centre (NHIC), The Pointer identified 80 endangered, threatened, or species of special concern present across these 43 parcels of land. In addition, there were two extirpated species and four restricted species — species that are so rare they cannot be identified for fear of trophy hunting or other illegal capturing activities. 

Thirty-four endangered species were identified in the selected development applications, 11 of these showed up across multiple applications in different municipalities. Nineteen of the species identified were classified as threatened, with seven showing up in multiple areas. Twenty-seven species of special concern were identified, 10 of which showed up in multiple areas across Southern Ontario. 

Of the 80 species at risk identified, 31 are birds, 6 are insects, 10 are fish or shellfish, 14 are plants, 15 are amphibians or reptiles and 4 are mammals. 

The level of potential loss of habitat for these embattled species is difficult to imagine. For the barn swallow, habitat is at risk of destruction in Markham, Pickering, Caledon, London, Guelph, Barrie, Ajax and Whitchurch-Stouffville. The red-headed woodpecker, an endangered species, stands to lose the forested groves it relies on to feed in Vaughan, Bradford, Oshawa, Oakville, Kitchener, and Barrie. The potential destruction extends to our province’s valuable waterways, harming those species at risk that rely on clear, cool waters to survive. The endangered redside dace will see habitat degraded or lost completely in Markham, Richmond Hill, Pickering, and Ajax, to name a few.  

The eastern meadowlark showed up in 77 percent (33 of 43) of the land parcels analyzed, representing the most impacted species identified by The Pointer. This included the risk of habitat destruction across the GTA in the municipalities of Vaughan, Oshawa, Richmond Hill and Markham. The Pointer found the eastern meadowlark stands to lose parcels of valuable remaining habitat across a swath of geography that stretches from Niagara Falls in the south to Huntsville in the north, and from Kingston in the east to Kitchener in the west. 

A collection of the species identified in The Pointer's investigation which are impacted by multiple development applications across Ontario.

(Alexis Wright/The Pointer)


This loss of habitat to breed and feed comes at a time when the eastern meadowlark and the bobolink, two birds that often share the same type of grassland habitats, are declining at disturbing rates. The chief cause of this decline according to Ontario's own recovery strategy for this species, the loss of habitat. 

The widespread presence of the eastern meadowlark and bobolink (which showed up in 24 of 43 parcels studied by The Pointer) is consistent with findings in Lysyk’s 2021 audit, which identified these two birds as two of the species most impacted by ongoing urbanization in Ontario. 

Analyzing permits granted to developers to harm species at risk, Lysyk found that 2,049 permits issued since 2007 directly harmed bobolink habitat. This comes at a time when current estimates suggest the bobolink population has declined by as much as 77 percent since 1970.  The meadowlark was not far behind, impacted by close to 2,000 permits since 2007, according to Lysyk’s audit. Government data suggests eastern meadowlark populations have declined 33 percent in the last decade. 

Without mitigation, habitat of the eastern meadowlark will continue to disappear, threatening the existence of the species.

(Jim Richards)


Other species facing widespread harm in Ontario identified in The Pointer’s investigation include the eastern wood-pewee, which is threatened by development applications across the whole province ranging from the GTHA, to Kitchener, Waterloo, Kingston, Ottawa, Barrie, Parry Sound, North Bay and Thunder Bay. Currently the eastern wood-pewee is labelled as a species of concern, but with development threatening its habitat across the province, it is at greater risk of becoming threatened or endangered.  The Midland painted turtle, present in 17 of the 43 development applications, and the snapping turtle (25 of 43 applications) are also both species of special concern. However, this status grants them no protection. 

In fact, for the 27 species of special concern identified by The Pointer, there are currently no plans in place to either mitigate the harm to these animals, plants and insects, or recover the species should it start to show drastic declines. But logic clearly dictates that is exactly what will happen should these species continue to lose habitat in municipalities across Ontario without any mechanisms in place to mitigate the harm. 

The Blanding’s turtle is another species being dramatically impacted by development across Ontario, evident by the findings of Lysyk’s audit and The Pointer’s investigation. Despite dramatic declines in population—as much as 60 percent over the last three generations—the Blanding’s turtle was still impacted by 9 of the 43 ongoing applications. Lysyk’s audit found the species had been harmed by 1,403 approvals under the Endangered Species Act that allow for development in areas that host sensitive habitats since 2007.

Despite the threats posed to a variety of species, Lysyk’s audit pointed out the startling reality that despite a species being impacted by development across Ontario, these myriad of applications are not looked at collectively. 

“Approvals are not assessed for how they cumulatively affect species at risk and their habitats…Instead, approvals are considered in isolation,” Lysyk wrote in the 2021 audit. “Yet the cumulative effects of multiple stressors—particularly those involving habitat loss—are what pose a significant threat to species.”

The findings of The Pointer’s investigation mirrored Lysyk’s audit in many ways, concluding harm to a species at risk does not happen in a vacuum, rather many individual species are threatened by a laundry list of development proposals across the province, attacking their habitat from all angles. 

The Pointer conducted similar analyses for the PC’s Highway 413, which identified 29 species at risk in the path of the proposed mega highway; and the Bradford Bypass (11 species impacted) both of which were included in this analysis. 

As part of her audit, Lysyk recommended the Ontario government begin to study cumulative effects, which would have a significant impact on the way Highway 413, the Bradford Bypass and the Greenbelt carve outs are assessed. The Ministry of Environment, Conservation and Parks ignored the auditor’s recommendation, refusing to begin considering what is blatantly obvious.

“The Environment Ministry did not commit to evaluating the cumulative effects of approvals and other threats, publicly reporting on this evaluation, and taking any necessary corrective actions,” Lysyk wrote.

Two years later, the province has not changed its ways and continues to put species at risk in harm's way. 

“It’s extremely concerning to learn that the Ford government is still set on ploughing ahead with their Greenbelt giveaway despite evidence that dozens of species at risk call those lands home,” Ontario Green Party leader Mike Schreiner wrote in a statement. “I am glad to hear that the federal environment minister has been made aware of the threat to the 29 species living on previously protected lands, and I hope he will take swift action to stop Ford’s environmental wrecking ball in its tracks.”

The 29 species mentioned by Schreiner is a reference to species recorded in a briefing note that was provided to Environment and Climate Change Canada and federal Minister Steven Guilbeault in March regarding at-risk wildlife present on the parcels of land up for removal from the Greenbelt, which was first reported on by Global News

It remains unclear whether the federal environment minister will use this data to intercede with the Greenbelt scandal. The federal Liberals have shown a willingness to intervene with provincial plans on behalf of species at risk in the past, albeit inconsistently. 

A previous investigation by The Pointer, using data from the Province's Natural Heritage Information Centre (NHIC), found the presence, or likely presence, of 29 species either listed as endangered, threatened or of special concern along the proposed route of the PCs prized Highway 413 in a six month period in 2020/2021. 

The presence of the endangered red-headed woodpecker along the path of the GTA West Highway corridor was one of the key reasons cited by MP Jonathan Wilkinson, minister of environment and climate change at the time and now minister of natural resources and forestry, for designating the project for a federal impact assessment. 

Despite the presence of the same endangered species along the path of the Bradford Bypass, a project which was also under consideration by his ministry, Wilkinson decided not to intervene, stating he had trust in the provincial mechanisms to protect species at risk and, by extension, the natural environment. However, the courts later ruled the federal government completely failed to review relevant information provided to them by citizens and environmental experts when making its decision. 

The impacts of the bypass are relatively obvious and, largely, the Province is already aware of its potential destruction. The 1997 Environmental Assessment for the project captured a snapshot of what is at stake. The highway would cross 28 different waterways decimating crucial spawning habitats for fish, destroy 22.1 hectares of “higher quality woodlands”, 17.2 hectares of the Holland Marsh, 9.5 hectares of provincially significant wetlands, 32.7 hectares of wildlife habitat, 190.37 hectares of “higher capacity mineral soils” and 154.3 hectares of active agricultural production. About 800 football fields of environmentally sensitive land will be either destroyed in full or degraded by the highway, which will also “severely impact” the quality and quantity or surface and groundwater.  

Experts have told The Pointer the negative effects will ripple out from the Holland Marsh into the entire Lake Simcoe watershed, which is already wavering on the edge of catastrophic failure as a result of ongoing urbanization. The same ripple effects will occur with other developments across Ontario. 

In November, the PCs passed sweeping legislative changes to the Greenbelt Act which would remove 7,400 acres of land from the protected greenspace and replace it with 9,400 acres elsewhere. The changes have been heavily protested by environmental activists for the hefty consequences including increased emissions, water contamination and habitat destruction they will cause. Experts also point to the misleading claim of offsetting, made by the PC government, which has asserted it is actually expanding the Greenbelt. Experts point out that just because new land is added to the protected Greenbelt elsewhere, there is absolutely no guarantee, or even any likelihood, that those lands will be as ecologically beneficial as the original lands. 

A previous investigation by The Pointer found nearly 30 species at risk along the proposed route of the 413 Highway.

(Joel Wittnebel/The Pointer)


The PC government is well aware of the species at risk whose habitats are located within the areas slated for development in any number of projects across the province. A study by Environmental Defence found 33 species at risk living within the Dufferin Rouge Agricultural Preserve, which is threatened by the changes to the Greenbelt Act, which could see it opened for development. One of these species is the monarch butterfly. But just because these species’ habitats are public knowledge now, does not give any indication that the provincial government is going to pull back or even alter its development plans. 

“[The PCs] are producing all sorts of soothing communications and everyone thinks ‘well because they’re doing all these studies they are going to mitigate or protect the environment because of this’,” Bill Foster, co-founder of the advocacy group FROGS (Forbid Roads Over Green Spaces) which is currently fighting the Bradford Bypass, previously told The Pointer. “What they’re really saying is we’re going to go through and find all the issues that are there, but that doesn’t mean we are going to mitigate them.”

Tim Grey, Executive Director at Environmental Defence told The Pointer that when the Ontario Endangered Species Act was developed in 2007, it was considered to be one of the best pieces of endangered species legislation in the world. But subsequent governments have continued to strip away at its policy, making it easier to build in sensitive areas, with stark consequences for our natural ecosystems. 

“The Ontario government has been very focused on rolling back protections for species at risk, both through the legislative changes, but also, they made changes to the Ontario wetland evaluation system this past fall,” Gray said. The wetland evaluation system changes that he is referring to came under Bill 23, which removed the presence of species at risk as a beneficial criteria when considering whether to provide provincially significant status to a wetland. 

While other provinces, and the federal government are realizing the need to study cumulative impacts, and moving forward with studies to implement this knowledge into their species at risk protection and recovery regimes, Ontario is lagging far behind. 

Back in February, the federal government launched a study that will look at the cumulative effects of any proposed activity alongside activities affecting the same species. Similarly, Quebec already considers the cumulative effects of both past approvals and other activities affecting a given species when assessing a new permit application affecting that same species or habitat. British Columbia is also beginning to consider cumulative impacts within environmental assessments. 

Ontario is actually going in the opposite direction, with legislative changes made as part of Bill 108, the More Homes, More Choice Act, which Lysyk stated may actually worsen the cumulative harm to species across Ontario. 

The legislation, passed in 2019, created what are now called landscape agreements. As Lysyk explains: “Previously, an approval would only be issued to a single entity to engage in a harmful activity at a defined location with limitations on the project size and the number of harmful activities allowed. However, landscape agreements can approve multiple harmful activities across a broader area, and beneficial actions may not occur for all impacted species.”

Instead of studying cumulative impacts and finding ways to reduce harm province-wide, the PC government is actually making it easier to cause widespread damage to the critical habitat of species at risk. 



Email: [email protected]

Twitter: @rachelnadia_

Email: [email protected]

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