The discussion paper leaves…

The discussion paper leaves us with more questions than answers. What new technology will be used to improve protections for species? How do you intend to protect species at risk?

The only area that is clear is how the review of the ESA will streamline paper work, and that it will only weaken an already insufficient Act. Although the objectives include better protections for species at risk, none of the suggested "improvements" would accomplish this goal.

The landscape approaches suggested in Area of Focus 1 already exist. Areas of Focus 2 and 3 exhibit a disproportionate focus on changing the listing processes and timelines involved in arriving at the implementation stage, rather than how recovery action is actually done. Even if longer timelines, greater transparency and an altered listing process do constitute a better system, they're superficial changes that won't do anything for species without the assurance that the government will put time and resources into recovery action.

But if anything, the proposed changes will negatively impact protections for species at risk. Please do not politicize the process by introducing "ministerial discretion on whether to apply, remove or temporarily delay protections for a threatened or endangered species, or its habitat." (p. 4). An endangered species is an endangered species whether politicians find it convenient or not.

The process of listing species as at risk, developing a Recovery Strategy and a Response Statement and then implementing it is disconnected enough without the added complication of ministerial discretion; nor do we have the time for extended deadlines. We want to see action now, because the longer we wait the more expensive and time consuming it becomes to clean up our mess, not to mention the money spent paying ministers to sit and discuss the matter and stall.

I am not comfortable with how the lack of improvements for species at risk balances against the heavy-handed efforts to lessen the "administrative burdens" on businesses, aka. make it easier for them to destroy ecosystems. We have already taken so much from the ecosystem that some species just can't afford to be sacrificed for economic benefit any further. Please do not make it even easier to achieve authorization for permits as suggested in Area of Focus 4, or allow businesses to get away with destroying biodiversity by paying a sum of money.

Instead, reduce the number of permits available for authorization and take action now to preserve our pollinators, our wetlands, and other species and natural habitats.

Thank you.