There are many issues with…

There are many issues with this proposal. The extremely limited definition of habitat is not reasonable; organisms need safe locations to feed, move, hibernate, and much more than just nest or breed.
The discretionary method of listing is also extremely concerning, as this opens the process up to ignoring real science and data and instead only listing convenient, non-controversial species. This is not enough to protect our environment.
The elimination of recovery strategies leaves species at risk with no definite actions set forward at listing, making listing itself much less targeted and meaningful.
Beyond this, there are many details missing in this proposal. There isn't enough clarity on how the SCA will be implemented, how registrants will actually be required to act, or public consultation methods.