I support the steps to…

I support the steps to reduce the duplication of effort and cost to support the bureaucracy. The ESA did complicate this CFSA planning process. I also expect that ESA concerns will continue to be closely considered during forestry planning via the CFSA process.
I am not certain that such things as tree clearing and hydro line installation have to be dealt with separately under the EBA as long as they are properly considered during the full CFSA planning process. Should these things come up separately to the plan process and implementation then yes, treat them by way of the EBA the same as you would if an EBA species unexpectedly made its presence known at any point in the forest operations. That said the Forest Operations Guidelines must be in place to speak to such occurrences.