Response to ERO 019-2636 "A…

Response to ERO 019-2636 "A proposal under the Endangered Species Act to enable use of the Species at Risk Conservation Fund and to streamline authorizations for certain activities that impact species at risk, while maintaining protections for species at risk"

The Ottawa Field-Naturalists' Club is opposed to the implementation of a proposal (ERO 019-2636) under the ESA to streamline authorizations for certain activities which impact SAR via a species at risk conservation fund. Once lost via habitat destruction or other anthropogenic activities, biodiversity preservation cannot simply be bought back via a fund as may be implicitly inferred by this proposal. Beyond this fundamental problem, if ERO 019-2636 is implemented as currently proposed, payments to the fund would be pooled and may not be used to help particular negatively impacted species and communities, and if aid subsequently occurs, it may be in a distant future. The plan for the fund additionally does not appear to involve long term government financial support. This proposal as designed, appears to encourage easier "streamlined" development and associated habitat loss/degradation in opposition to the goal of the Endangered Species Act. We urge the government to reconsider this proposal's details such that it can align with conservation of our Province's natural history heritage, or withdraw it entirely.