API Comments to FWS for Revisions to Regulations for Eagle Take Permits (July 5, 2016)
The American Petroleum Institute (API) submits these comments on the U.S. Fish and Wildlife Service’s (FWS or “the Service”) proposed revisions to its Regulations for Eagle Incidental Take and Take of Eagle Nests (81 FR 27933, May 6, 2016).
Members of API regularly engage in activities that may require an eagle take permit under the Bald and Golden Eagle Protection Act, 16 U.S.C. §§ 668–668d (“Eagle Act”). API supports the goal of the Service to enhance protection of eagles throughout their ranges through implementation of avoidance and minimization of, and compensatory mitigation for, adverse impacts from otherwise lawful activities, and believe this goal can be achieved in conjunction with responsible development of our nation’s natural resources. As these comments will explain, however, we have recommendations for this program, in order that it may achieve its objectives and avoid unreasonable burdens on the activities of our industry.
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