Thank you for the…

Thank you for the opportunity to comment on the proposed changes to the ESA. I strongly oppose the changes that are being considered. They will not improve outcomes for species at risk. On the contrary, they would make it easier for industry and developers to destroy the habitats of our most vulnerable plants and animals.

First, I do not support changes which would introduce broad ministerial discretion to interfere with the science-based listing process, to suspend and limit protections, and to ignore legislated timelines for policies and reporting. Lengthening the time between the COSSARO's identification of a species as being at risk until it is placed on the SARO list will only allow developers to continue to destroy habitat for a longer period of time. Once habitat is gone, it is very hard to get it back. Species can move to
higher risk of extinction before action is taken.

Nor do I support the “pay-to-slay” scheme that would grease the wheels of destruction by allowing developers and other proponents of harmful activities to pay into a fund in lieu of fulfilling requirements for on-the-ground reparation for the damage they do to species and their habitats. Once again, this allows for developers to continue to destroy habitat with impunity.

I also do not support the political interference of the Minister being able to require the COSSARO to reconsider a designation. Designations are science-based and should not be overturned by political agendas. Again, adding this step to the process only lengthens the time that species are not protected. It is clearly pro-developers.

I am also concerned about the recommendation to "broaden" member qualifications for the COSSARO. Presently, the qualifications are as follows:

a) a scientific discipline such as conservation biology, population dynamics, taxonomy, systematics or genetics; or

(b) aboriginal traditional knowledge.

It seems to me that these already include a broad range of scientists including the fields identified by the suggested changes. For example, Population dynamics and conservation biology would encompass wildlife management and ecology. The only new category is people with "community knowledge." Does that mean anyone who lives in the community, say, like a developer? I believe this is too broad a category. We already have indigenous people identified as a component. I see no need to open it up further.

Improving outcomes for species at risk requires enforcement, not weakening, of the law. It also requires investment in stewardship, not writing off species at risk and their habitats as red tape.