Jul 1, 2015 IPAA and API Comments to the U.S. Fish and Wildlife Service on its Interim 4(d) Rule for the Northern Long-Eared Bat
The Independent Petroleum Association of America (IPAA) and the American Petroleum Institute (API) are filing these comments to further demonstrate, based on the new explanatory information about the treatment of timber harvesting, that the record compiled by the U.S. Fish and Wildlife Service (FWS) does not support disparate treatment of timber harvesting and oil and gas activities. As shown below, there is no rational basis for the distinction that FWS attempts to draw between these two types of activities in terms of their potential impact on NLEB habitat. Accordingly, IPAA and API renew their request that the final 4(d) rule for the NLEB exempt oil and gas activities from the prohibition against incidental take. A failure to do so will impose unnecessary and costly burdens on the oil and gas industry and FWS itself and will not result in a measurable conservation benefit for the NLEB.