Without significant revision…

Without significant revision, definitions and processes described in the proposed act may reduce species protections.
1. I am in agreement that the definition of "habitat" in the ESA is vague. However, the definition in the proposed SCA limits "habitat" beyond what is effective for conservation. For instance, the definition contains no mention of feeding. Many animals travel away from their primary dwelling place and its immediate surroundings in search for food (whether this be prey species or plants). To truly be protected, an organism requires more than its dwelling and the area immediately surrounding it. I urge the government to further consult ecologists and biologists to create a definition for "habitat" that is clearer than in the ESA, but not as restrictive as what is being proposed.
2. The removal of harassment as a harmful act towards species at risk is highly questionable. Excessive light, noise, and human activity have been shown to influence reproductive success of animals. As an example, see the linked paper ("Negative impact of traffic noise on avian reproductive success") for one of many studies on noise pollution.
3. The registration-first approach seems self-defeating for a conservation act. These are protected species; their protection should not be compromised in the name of speeding up projects. However, if a registration-first approach is opted for, on-site assessment must be rigorous, begin early in the project's development, and occur periodically. I would like to see the requirements for such project assessments in writing. It is mentioned that the registration-first approach has been "successfully used for many species and other environmental authorizations"--I am unsure of where to find examples of this, and would appreciate if such examples were cited.