You say that "the Act has…

You say that "the Act has been criticized for being ineffective..." and list complaints. I think it is not the Act that is ineffective, but how it has been implemented. The failure to protect and recover, and the complaints of people, come from bad implementation.

In this review you suggest changes that would weaken protection more, on top of the history of poor implementation of the Act. You say nothing about fixing the massive weakening of protections in 2013 caused by a permit-by-rule system which exempts industries from having to get permits for many common harmful activities and does not monitor compliance with the rules. This system was implemented in a way which reduces protections for species at risk, does not require overall benefit, and lacks oversight, enforcement, and public information about use of the system and harms being done.

This review does not address the 10-year failure to implement the ESA effectively. Instead this is a proposal to change the ESA to help the government to further delay real commitment and action to protect species at risk, and to help business interests to more easily exploit the exemptions allowed under the Act and its regulations, and even offer them new ways to get around compliance.

Species at risk will not be helped by longer timelines for listing, ministerial discretion to interfere in listing, weakening automatic protection, and subjecting the findings of COSSARO to "review". Species at risk will not be helped by delaying response to assessments and delaying review of progress toward recovery. Species at risk will not be helped by providing more ways and simpler ways to obtain exemptions from provisions of the ESA.

I would suggest instead to implement and administer the existing provisions of the Act in a way that is effective. Enforce the provisions of the act. Fix the permit-by-rule system that should not be used for major industrial activities at all, and should not allow industry to self-monitor and hide the impact of their activities.

Most of all what is needed is a government commitment to actually stand up for species at risk. Treat species at risk as a matter of urgency and importance. Do not cave in to industries who place their interests ahead of species at risk. Invest far more resources in species and habitat protection, assessment, response, recovery, monitoring and communication.