Industry Trade Associations Joint Comments on the U.S. Fish and Wildlife Service’s Draft Endangered Species Act Compensatory Mitigation Policy

Industry Trade Associations Joint Comments on the U.S. Fish and Wildlife Service’s Draft Endangered Species Act Compensatory Mitigation Policy

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, submit these comments on the U.S. Fish and Wildlife Service’s Draft Endangered Species Act Compensatory Mitigation Policy. The Trades share the Service’s interest in improving the efficacy and efficiency of the conservation programs implemented pursuant to the Endangered Species 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. The Trades’ member companies are proud of the conservation benefits that have been realized through their participation in compensatory mitigation, and strongly wish to see the Service’s compensatory mitigation program structured in a way that maintains a focus on conservation and incentivizing participation. As such, we encourage FWS to allow stakeholder to use all the tools in the conservation toolbox and not use the Draft Policy to favor certain specific mitigation instruments.

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