I read this proposal with scepticism. I understand that this new "conservation" fund is being established in order to cut the "red tape" proponents face when filing for an overall benefit permit when it is discovered that species-at-risk will be negatively impacted by a project/development. An overall benefit permit is required under the ESA in order to reduce these impacts. How does a central fund provide benefit/protection to a species locally? Species exist and thrive in areas that are protected. Creating a new, artificial habitat elsewhere does not protect the species locally. All this fund does is eliminate the responsibility of the proponent to provide necessary and critical protection to species that are at risk. So in reality, proponents pay to kill off these species so that their projects can go ahead in a more expedited fashion. It is an offense under the ESA to kill, harm or harass the species listed in this proposal, or damage or destroy their habitats. How does this fund possibly allow them to receive these protections? Think of this scenario if you will: What if the species in question were human beings? It is against the law to kill another human being; however, if the government of the day charges a fee, it can build an artificial insemination depot down the road, and thus, save the species. Would this action be morally acceptable? No. This proposal is immoral and just simply wrong. By providing this fund the government is putting these species at further risk.
Submitted December 16, 2020 3:27 PM