In the introduction of this…

Numéro du REO

013-4143

Identifiant (ID) du commentaire

23643

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

In the introduction of this discussion paper, it is written that the government is “committed to ensuring that the ESA provides stringent protection for species at risk”. However that does not appear to be the intent of any of the rest of the document’s contents.

All of the challenges and discussion questions listed are highly biased towards helping businesses and developments increase profits while side-stepping any responsibility for local species at risk.

In particular, allowing companies to pay into a “conservation fund” and then interfere with at-risk habitat & species located on their land is a terrible idea. Those species and their habitats would be lost, and no amount of money sitting in a “fund” would be able to bring them back. Ecology doesn’t work like that.

Also, bringing in “ministerial discretion” would be a bad idea. It would be unethical to allow decisions on species at risk to be politically driven instead of science-based.

For the other challenges that were listed in the paper – who raised those questions? Most of their concerns sound like they are just asking for improvements to the way the system is managed (i.e. better communication, more staff to conduct reviews, etc.), not an overhaul of the Act itself.

If the government really wanted to change the Act to ensure that species at risk are protected, then different changes would make more sense, like getting rid of those blanket exemptions that are currently in place for mining operations, hydro works, and the rest of them. Those exemptions really seem to defeat the point of the ESA.