I am opposed to the proposed…

I am opposed to the proposed interim changes to the current Endangered Species Act, 2007 (ESA) - immediate amendments designed "to speed up project timelines and provide greater certainty for proponents".

When a project is proposed, ecological field surveys must be conducted to determine whether the associated activities may negatively impact species at risk and/or their habitat. The information collected must be of sufficient detail to identify all impacts and inform a permit process if mitigation of negative impacts is not possible. Natural environment features and functions, particularly those supporting species at risk, are inherently complex and time-consuming to assess and define in a permit. The permit process should not be considered an "unnecessary delay" that can be bypassed. Species should not be considered protected before the permit is obtained.

The registration-first approach available for projects that involved species and site conditions with common, predictable impact assessment and mitigation did not apply to other circumstances for a reason. Implementation of this approach for more complex situations will result in widespread species at risk losses.

Narrowing mitigation to activities "most likely to have a direct negative impact on species" also under-estimates the complexity of natural environment systems. Indirect impacts and impacts over time can be major determinants of species' survival.

Species at risk recovery must emphasize protection of existing habitat, given the complexity of ecosystems and the poor success rate of species at risk in restored or created habitat.

The protection of species at risk and their habitat is part of securing social and economic health over the short and long term.

COSSARO must remain the authority. This committee was created to ensure that decisions on species listing and delisting are science-based; unaffected by political and developer preferences.