Observations from Lic. Saade

1. The project represents the most serious threat to the protection of human health and the environment from the origin of the environmental legislation of the 1970′s.
2. Intensified deterioration of land uses and environmental protection, particularly in the absence of a Land Use Plan.
3. It is not a law to amend reasonably permits but seek to exclude involvement in permitting use of land. It is profoundly anti-democratic.
4. Actually excludes the courts,
5. It involves the dismissal of public employees.
6. Seeks to reinterpret the constitutional protection clause of article VI, sec. 19 and other protections to citizens.
7. The law creates a complex structure of several components that may be ineffective.

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Analysis by Jose E. Rivera Santana:

This document highlights the most damaging aspects of the permit proposed law.  They will be in red and underlined.  To the best of my knowledge the following should be emphasized:

1. The “Certified Professional”.  This is some kind of  mercenary that will give permits left and right, to the highe$$$t bidder.
2. The Office of Permit Management will prepare the environmental documents and will also evaluate and approve them.  That is, it turns into judge and concerned party.
3. The payment required for the revision of an approved final permit is a violation citizen´s rights, it is discriminatory and unconstitutional.
4. The agencies like DNER, EQB, DA, among others, will turn into supervisory agencies but only at the end of the process, when the permit has already been given.
5. The creation of the Appeals Board pushes out and marginalizes the courts to become a certiorari recourse…..
To summarize, this is a major atrocity and the culmination of the process of giving our heritage to the private sector.  Furthermore, it is an invitation to anarchy regarding the use of resources and a call for confrontation with communities and the country in general.

José E. Rivera Santana