I wish to make known my…

I wish to make known my opposition to this proposed change based on the following reasons:

Key concerns include:

Narrowing the definition of habitat to only include areas of breeding, rearing, staging, wintering, or hibernation disregards the complexity of species’ life cycles and ignores vital habitat functions such as foraging, migration, and shelter. This shift opens the door to habitat destruction under the guise of clarity.

Removal of “harassment” from prohibited activities eliminates an important protection against indirect but harmful disturbances to at-risk species. This move directly echoes harmful U.S. policy rollbacks and disregards well-established ecological science.

Replacing mandatory recovery strategies with a vague “flexible approach” removes accountability and transparency. Without required recovery plans, there is no legal obligation to act decisively in the face of species declines.

Transitioning to a registration-first model is deeply troubling. It enables proponents to proceed with development in sensitive areas without adequate oversight or impact assessment. This “don’t look, don’t see” approach avoids the hard work of responsible stewardship.

Government discretion in listing species introduces a political filter into a process that must remain independent and science-based. While COSSARO assessments remain, they are meaningless if the government can simply choose not to list a species.

Removal of the option to pay into the Species at Risk Conservation Fund without a clear, enforceable alternative to fund on-the-ground action could further starve conservation efforts of resources.