To whom it may concern, I…

I would like to comment on the changes to the Endangered Species Act that have recently been proposed. Each of these four concerns has been carefully weighed and no significance should be placed upon their order.

First, I am disappointed and gravely concerned that sufficient time has not been allowed to assess the consequences of the changes proposed. I understand that the Bill that contains these changes is already in its second reading period and that the motion was carried in its first reading. I conclude from the concurrent debate and consultation processes that the latter is considered insignificant to this Government.

Second, the intention is to improve an act that is currently “ineffective in its aim to protect and recover species at risk" (from the Discussion Paper). The changes proposed do not seem to help with species protection or recovery. Instead, they appear to facilitate impacts to these species and their habitats by taking decision-making away from experts and giving it to politicians. For example, I am particularly concerned about giving the minister power to suspend protected species' status. If the aim is truly to make this legislation effective at protecting and recovering species, I would like to see those provisions spelled out and additional consultation take place.

Third, the Government is aware of its duty to consult with First Nations relative to any developments that take place within their territory. It was my hope that the one of the updates to this Act would articulate more fully how this duty would be fulfilled. I am disappointed that this communication is missing from the proposed changes.

Lastly, it is simply impossible to protect and/or recover a species without protecting its habitat. Eliminating or suspending, no matter how temporarily, the legislation of protected habitat can only have negative impacts on the species.

Thank you for your consideration.