Removing the concept of …

Removing the concept of "harass" from species protections will negatively impact species that require protection. Harassment can lead to heightened stress levels and even mortality of the individual(s) affected.
The proposed change to the definition of "habitat" is too narrow. The previous definition from 2007 is more scientifically, logistically, and ethically appropriate. Which is: "an area on which the species depends, directly or indirectly, to carry on its life processes, including life processes such as reproduction, rearing, hibernation, migration or feeding" (see S.2 for further detail). The proposed changes to the definition of habitat should be added to the existing definition, but should not replace that definition entirely.
Having a permit to do an activity should not be viewed as more important than conserving/protecting the species that will be impacted.
So called "duplication" of requiring authorization under federal and provincial species at risk legislation is in place to ensure species receive the protection they require.
Removal of the requirement to develop recovery strategies and management plans, government response statements, and reviews of progress is unethical and irresponsible. The government and the private industry is authorizing to do work in sensitive habitat should be held accountable for any harm they do to the environment, as that harm will have impacts on human health, wellbeing, society, and economy for generations. Conservation "when it makes sense to do so" sounds a lot like creating a legal loop hole that businesses and irresponsible governments will take advantage of.
Allowing permits to be registered before project proposals have been screened is irresponsible. It allows for error. It is actually a potential waste of time for all parties because if the project is deemed unsuitable, then the permit must be revoked. Unless of course these proposed changes were designed to allow all permits to be authorized. In which case, as previously stated, that is extremely irresponsible. Faster is not better. If you eat through an entire winters worth of food when there are still many months till spring, you have not won the race, you have committed yourself to failure.
Voluntary and mandatory conservation activities are both important for achieving compliance with permit holders. The proposed increase in investing in a wider range of voluntary conservation activities has the potential to be beneficial for everyone.
Removing the Species at Risk Conservation Fund and the previously required species conservation charge will decrease capacity for conservation efforts.
The Species at Risk Program Advisory Committee is important and useful, and therefore should not be dissolved.
Enforcement of the ESA is important. The proposal to update compliance and enforcement methods could be beneficial.
The registration first approach without ministry review removes a layer of protection from species that need it. Online applications do not guarantee that applicants understand and are in compliance with the rules. Review from ministry staff should ensure that the application is up to par, and this wait time provides a temporal buffer to potentially affected species. "Upgraded IT" should not include AI, as AI should not be trusted to make important permitting decisions, and the use of AI is very energy expensive and harmful to the environment.
The existing Endangered Species Act protects species and their habitat. This projects wetlands, forests, grasslands and other ecosystems. These ecosystems provide billions of dollars worth of ecosystem services, such as flood mitigation, water filtration, carbon storage, and enjoyment. These habitats are not isolated islands or planets in space. These habitats are connected, and need to be so in order to function properly. Biodiversity supports economic growth, agriculture, clean drinking water and air, tourism, Indigenous treaty rights, and more. A responsible government would not weaken existing legislation which provides these protections. A responsible government would enhance and enforce policies which recognize that economic growth cannot exist without healthy, interconnected ecosystems.