I have many concerns about…

I have many concerns about the proposed changes to the Endangered Species Act, which I have outlined below.

1A. By extending the time when when a COSSARO report is received by the Minister to when listing is to occur from three to twelve months you provide opportunity for the act to be exploited. Within those twelve months development could occur rapidly causing irreparable damage to the listed species. There is no benefit to the endangered species by extending this time, and three months is already reasonable.

1D. COSSARO consists of expert scientists in conservation biology. By allowing the Minister to require COSSARO to reconsider the classification of a species you are ignoring science and delaying the protection of endangered species. This also allows the Minister to delay controversial listings, further weakening the protections of the act.

1E. "If the overall condition of risk to the species in the broader biologically relevant geographic area is lower, COSSARO would be required to adjust the species’ classification to reflect its overall condition." COSSARO already considers the condition of the species in a broader biologically relevant geographic area during the assessment progress. I am concerned that this change will make it difficult to list species with a broad range until they are in decline everywhere. Recovery is more likely to be successful when protections are implemented sooner. This change also ignores the many reasons why conserving species on the edge of ranges is important.

F. It is not clear who would be included by broadening COSSARO member qualifications to include members who have relevant expertise in ecology, wildlife management, as well as those with community knowledge. Scientists and those with traditional indigenous knowledge are already included, and it seems this change is a way to non-scientists in COSSARO. COSSARO should include scientists who do not have pressures from other sources impacting their priorities.

2A. Keeping the science-based assessment process "at arm's length" from decision making regarding protection of species is outright irresponsible. Further, by allowing a three year hiatus on implementing protections, you are putting the species at further risk for the sake of development. The purpose of the act is to protect endangered species, and this change is basically a giant loophole to only protect species when it is convenient. By the time the three year hiatus has finished, the species may have experienced further declines from which it cannot recover.

3A. Listing a species is already a time consuming process, and when population declines are steep action needs to be taken quickly. Extending the response statement timeline unnecessarily lengthens the process, and provides a way to slow down the listing of controversial species. There is no reason to extend this timeline, and this amendment should be removed.

3C. Again, extending timeline causes unnecessary delays which can provide developers to finish projects in areas that should be protected and a way to slow down the listing of species.

4. The so called "Pay to Slay" weakens the act by making assumptions that are known to be untrue for many taxa. Habitat that is destroyed cannot simply be replaced somewhere else for a net zero effect. Ecosystems take time to become established, and may not provide the same resources to endangered species as the original habitat.

4B. By shifting the approach from individual species to species more generally, the act is ignoring cumulative impacts. In most cases a species is not threatened by one thing. Rather many small impacts add up to cause a decline. Many small scale impacts will add up to impact the species as a whole.

4E. Landscape level agreements should be used with caution because they can ignore site or species specific issues and cumulative impacts. If a landscape agreement is implemented, effort should be made to include the requirements of specific taxa that are to be protected.