ESA Cross-Industry Coalition on ESA Proposals
The ESA Cross-Industry Coalition, comprised of the American Gas Association, Association of Oil Pipe Lines, American Petroleum Institute, International Association of Geophysical Contractors, Interstate Natural Gas Association of America, National Association of Home Builders, National Association of Manufacturers, National Rural Electric Cooperative Association, and the Utility Water Act Group, submitted comments in response to the three proposals from the U.S. Fish and Wildlife Service and the National Marine Fisheries Service to amend their Endangered Species Act regulations.
The proposals, if issued as final rules, will have important – and in many circumstances beneficial – implications for a wide range of activities undertaken by the Coalition’s members, for the public, and for efficient and effective conservation of listed species.
The Coalition endorses, and is encouraged by, the Services’ efforts to clarify and improve their ESA regulations, and to reduce duplication and inefficiency, so that the Services, the regulated communities, and the public can focus their limited resources on actions that truly improve environmental outcomes. We support many of the Services’ proposed modifications, which are consistent with the Act, its legislative history, and the case law, and reflect concerns the Coalition expressed in prior comments and litigation. There are a number of areas, however, where changes to the proposals are warranted to ensure consistency with the statute and settled precedent and to improve implementation of the Act, these areas are detailed in the submitted comments.
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