Hello, I am writing to…

Hello,

I am writing to provide comments on the “Proposed interim changes to the Endangered Species Act, 2007 and a proposal for the Species Conservation Act, 2025”, ERO # 025-0380.

I do not support the proposed changes outlined in the proposal. I have significant concerns with the following:

1. Registration-first approach
• This approach allows proponents who wish to harm species at risk and/or their habitat to go through with their activities without government oversight. Most people don’t know what species at risk (SAR) may be located on their property, let alone how to mitigate impacts a project may have on them.
• This approach is likely to increase habitat destruction for species at risk and further exacerbate their decline

2. Species Classification and Listing
• For the government to have power to add/remove species at risk to the list of protected species is unacceptable. This list should be based on scientific evidence provided by qualified experts. For the government to have the power to add/remove any species defeats the entire purpose of having a list of protected species.

3. Redefining “Habitat”
• Again, an unacceptable change. Currently habitat definitions are unique to each species, which it should be as each species is unique and has a different set of habitat needs. For “habitat” to be so narrowly defined will undoubtedly result in declines in species. For example, the proposed change for vascular plants is to change the habitat for all plants to the critical root zone surrounding a member of the species. How will this protect the species in the long-term? For example, if this change were to occur as proposed to a plant like American Ginseng, which lives exclusively in shaded, deciduous forests, it would only have habitat protection of the plant and the area the roots extend to. But the forest in which is depends could be destroyed? How will this plant survive? How will it reproduce?

Thank you for reading and considering my comments in this proposal.