Comments on the U.S. Fish and Wildlife Service’s Draft Endangered Species Act Compensatory Mitigation Policy
Letter commenting on the U.S. Fish and Wildlife Service’s draft ESA Compensatory Mitigation Policy, as filed August 17, 2016 in a joint effort of AXPC, API, IAGC, IPAA, and Western Energy Alliance.
The American Exploration and Production Council (AXPC), American Petroleum Institute (API), Independent Petroleum Association of America (IPAA), International Association of Geophysical Contractors (IAGC), and Western Energy Alliance (“The Alliance”) (collectively “the Trades”), submit these comments on the U.S. Fish and Wildlife Service’s (FWS or “the Service”) Draft Endangered Species Act Compensatory Mitigation Policy (“Draft Compensatory Mitigation Policy” or “Draft Policy”).1 The Trades share the Service’s interest in improving the efficacy and efficiency of the conservation programs implemented pursuant to the Endangered Species Act (ESA or “the Act”); however, we are concerned that the Draft Compensatory Mitigation Policy will not bring forth the clarity, predictability, or transparency that the Service anticipates. Indeed, we believe that the Draft Policy, if finalized as proposed, is too complex, would only deter participants from engaging in compensatory mitigation, and would make the Service’s approach to mitigation more costly, burdensome, opaque, and unpredictable.
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