The Endangered Species Act …

The Endangered Species Act (ESA) already covers all necessary fields to effectively protect and assist in recovery of species at risk. The main issue with the ESA currently is lack of implementation, not lack of regulations or guidelines. The length of time it takes to list a species at risk and develop a recovery strategy is part of the problem. Improvements should be made on equipping agencies that write recovery reports with enough people to shorten the time it takes to assess species and begin the protection process. Providing more funding to the implementation and creating more jobs for scientists to research recovery strategies would help make the ESA more successful as it is currently written. There is no need to change the ESA.

The ESA already covers a multi-species approach which is ultimately a landscape approach. There is no need to change the ESA in this regard. Science-based evidence of decline and recommendations for recovery are vital along with automatic protection of species and their habitats.

The role of COSSARO and the ESA listing process should remain the same. The ministry should have no say once the science shows that a species is at risk, those species should be automatically protected including their habitat.

The recovery policies and habitat regulations that are currently in the ESA are effective and should remain untouched. The current issues in this section, again, are related to implementation, and there is no analysis that explains why these timelines are not currently being met. The government should be legally responsible to create the Government Response Statements on time. Again, this issue could be solved with an increase in the number of people tasked at writing these statements and reports.

The ESA currently provides enough authorization tools, and challenges should be handled by improved implementation. Paying into a conservation fund to conduct harmful actives is not a fair compensation. Ecosystems take a long time to reach their stable state and once they are disturbed, it can take decades for them to recover.

Lastly, listing species based on their range across North America is not a sustainable way to protect species long term. Individuals at the edge of the species range (I.e. if a bird lives in the southern US for winter and flys to Ontario to mate, but most of the individuals of the species stops in Detroit to mate, the Ontario population is at the edge of the species range) have adapted to different climates, food sources, and habitats than those at the centroid of the species range. These individuals could have novel evoluationary potential and may be the ones that can survive in the unknown conditions that anthropogenic climate change will bring.

In general, I feel that without a healthy, thriving natural environment, industry will collapse eventually in the face of anthropogenic climate change. We need healthy natural environments for the ecosystems they provide. Permitting industries to destroy species at risk habitat should be made more difficult as it is very rare that companies can restore those habitats to the same quality of habitat function and services. The ESA is not the place to put industry first. There is no need to weaken the law but rather a need for better implementation. We are not seeing species recovery because we are not actually following the laws already in the ESA and ensuring that once a species at risk is located, their habitat is then protected. The purpose of the ESA should first and foremost be to protect species at risk and their habitats, not encourage business development.