Are there any additional considerations which, in your view, can improve ...

These regulations are a terrible over reach. Species that are established here and seeding wild cannot be controlled mechanically. look at the effort it takes to keep Nonsuch Island in an original state. It is not reasonable to expect citizens to do this. (Government can't do it for parks either) When people came tot he island there were, 3 endemic and 7 native species of tree. Look a the old paintings, there was nothing here. To be honest, I prefer it now. If picking loquats and cherries means i have to put up with peppers trees and laurels; well, at least laurels give good shade and are fun to climb. These regulations should be focused on making a public list of species, which are not ALREADY HERE, which would be dangerous and should be kept out as far as possible. then make it an office to bring them in and grow them. And when I say a 'Public' list I mean a list that all the public can access, but also one that the public periodically gets to discuss and have input in amending. Not one that is decided on by a hidden group of government employees. As my grandfather used to say; Bad laws make criminals of everyone.

The Bill would make it an offence to possess / grow / cultivate / sustain a prohibited invasive species. I'm not too familiar with the species that are deemed to be prohibited invasive species. I am guessing that they are ones that are not presently really in Bermuda, but could become a threat if they came here. The problem is that, as they are invasive (and not recognisable in many cases), somebody could be in possession of them without even knowing they are on their land. Do we really want to be criminalising people for ignorance of what is invasive? I believe a defence of ignorance needs to be added to the offences. Or, even better, that it only becomes an offence once somebody continues to possess etc. after having been given a reasonable opportunity to dispose of it. This Bill would make it a criminal offence to release a lizard that has found its way into your home - or simply to allow it to escape. An illustration of how this law is drafted. It will also make it illegal to grow or cultivate various very common plants around Bermuda, including morning glory, wild mimosa, chinese fan palm, brazilian pepper, wedeila... Grow or cultivate are undefined. Arguably it includes having things growing on your land, regardless of whether you are actively cultivating them. I don't believe we should be criminalising people who happen to have these plants on their land. I dread to think how much herbicide is going to be drenched over Bermuda to try and kill off all the invasive plants once this comes into law. I would also suggest that, as a matter of policy, we should be more focussed on allowing people to focus on planting strategies that promote food-bearing plants, rather than a narrow focus on native plants which frankly don't seem to do that well when the broader habitat has already disappeared.

What is the difference between "possessing" and "growing" an invasive species? I note that possessing a prohibited species is an offense, possessing a restricted species is not.

Maybe I missed it, but there doesn't seem to be any guidance as to what conditions will be evaluated by the "bio-risk assessment" or considered by the director in determining whether to issue a permit/license, leaving a great deal of discretion to the director and very little guidance for the public. This is particularly concerning with regard to the transition phase, where existing plantings will be evaluated. Will, for instance, the cost or damage required for removal be considered? Some of these invasive species are large and difficult to remove.

There needs to an assessment of what this will cost, both government (inspecting, making plans, enforcing on the ground and in court) and to individuals, as many of these species are large and very expensive to remove. Has this assessment been done, and is it publicly available?

If/when a permit or a license is issued, what provisions are in place under the Act which allows the Director to enter the premises to ensure his considerations or restrictions are being adhered to? Apologies, if this is covered in the draft and I overlooked it. Also, great to see this initiative!