Sep 4, 2020 API and IPAA Comments on the U.S. FWS’s and National Marine Fisheries Service’s Proposal to Define “Habitat”
This letter provides comments from the American Petroleum Institute (“API”) and the Independent Petroleum Association of America (“IPAA”) (collectively, “the Associations”) in response to the U.S. Fish and Wildlife Service’s (“FWS’s”) and National Marine Fisheries Service’s (“NMFS’s”) (collectively “the Services”) proposal to define “habitat” in the Services’ regulations implementing the Endangered Species Act (“ESA” or “the Act”). The Associations appreciate the opportunity to submit comments on this important effort to develop a regulatory definition to an undefined statutory term, and to do so in a way that can help ensure that the Services’ critical habitat designations are clear, transparent, and consistent with the ESA’s requirements.
