Framing the current…

Framing the current Endangered Species Act as doing nothing but "causing unnecessary delays and costs for housing, transit, and critical infrastructure" is dismissive of the inherent nuance associated with conservation efforts, and the time it takes to meaningfully effectuate them. The reality is that such "delays", as they may be considered in the rest of the industry, are actually critical for conservationists to properly assess the actions necessary to take for effective ecological protection. As an undergraduate B.Sc. student currently studying biodiversity and conservation ecology, I am of the whole-hearted belief that in our current times of dire environmental change, it is now more than ever that we should be enforcing stricter policies to preserve our already fragile Earth, not easing up on them. Higher industrial efficiency will mean nothing in the face of a barren planet in which its resources were hastily used at the expense of the lifeforms that we shared it with.

Below I am quoting some more specific statements in this proposal whose intentions I question or disagree with:

[Species Classification and Listing]
"However, the government would have discretion to add extirpated, endangered, and threatened species to the list of protected species. The government would also have discretion to remove protected species from the list."
We need to be completely honest with the fact that the government will not prioritize the addition of new species to be protected. The task of assessing species is currently and only assigned to the scientific community because they are the ones with the nuanced insight of the ecological roles and contexts species are placed in, and how such roles hold importance when assessing the potential risks they face. To give this authority to a group lacking these insights is to also undermine the unique importance of these scientists' expertise.

[Recovery Plans and Documents]
"...however, the rules set out in the current ESA are too rigid and often result in duplication with federal recovery documents... The proposed amendments to the ESA would remove the requirements to develop recovery strategies and management plans, government response statements, and reviews of progress from legislation."
The enforcing of numerous steps across the levels of government and submission of progress to legislation is key to ensuring the correct decisions are being made, and at a reasonable, sustainable pace. Without these chances to proofread and monitor, the integrity of decisions are far too hasty and lack consideration of collective perspectives reflecting the unbiased needs of the community and environment. It is also integral to recognize that conservation ecology exists as a crisis discipline- meaning it serves to respond to crises and mitigate their severity. By removing preemptive recovery strategies and planning, this sabotages conservation efforts entirely, and proves an incredibly short-sighted form of management. If no prevention measures exist, how can effective responses that scramble for solutions only after the damage is done possibly be expected to be more successful?

[Registration-first Approach]
"Under the new registration system, proponents will be able to get projects started as soon as they have completed their online registration, provided they are following the rules in regulation. This eliminates the step of waiting for the ministry to review and approve permits."
Once again, this change would do nothing but enable hastier, less sustainable practices. Permits associate a stronger sense of responsibility with the action they allow, proving their holder is reputable and fit to perform such actions- regarding them as nothing more than a barrier for progress is ignorant. Allowing just anybody to register removes this accountability, and if anything, sounds contradictory to the supposed goal of streamlining effective progress. How is the eligibility of quality work that will actually benefit the community to be assessed without ministry revision? How will the risk of parties exploiting this less restrictive system be prevented?

With this said, I deeply implore this proposal to be reconsidered, as its intentions do not reflect my and countless others' values as environmentalists and democrats who simply advocate for sustainability. There are far too many changes in this document that open opportunities for leniency and neglect of conservation, and do not truly have the best in mind for the ecological concerns they claim to be in support of.