Thank-you for this…

Thank-you for this opportunity. While improvements to implementation of the Endangered Species Act are warranted, I am concerned that the proposed changes to the Act itself will reduce the effectiveness of the legislation to protect individual species and the overall biodiversity of our environment. In particular, I note the following:

1. In sufficient details have been provided with respect to the proposed Species at Risk Conservation Trust. It is important that the Trust be designed to ensure that timely, on-the-ground recovery actions are the required first course of action unless it is demonstrated that the cash-in-lieu approach will provide a larger net benefit to the species within the same general geographical area as the proposed disturbance.

2. With respect to Issuing Permits, the proposed changes to Section 18 remove the requirement to demonstrate an overall benefit to the species. The proposed "best efforts" phrases will likely be insufficient to protect these species in the long run.

3. I am concerned that the removal of the mandatory legislative requirement and timeline to develop habitat regulations for each newly listed species will result in prolonged delays in creation of the Regulations necessary to protect the Species at Risk.