Industry Trade Associations Comments to the U.S. Fish and Wildlife Service on its Endangered Species Act Compensatory Mitigation Policy

Industry Trade Associations Comments to the U.S. Fish and Wildlife Service on its Endangered Species Act Compensatory Mitigation Policy

Dear Mr. Sheehan: With this letter, API, IPAA, AXPC, IAGC, and Western Energy Alliance (together “the Associations”) are pleased to submit these comments in response to the captioned public notice, published in the Federal Register November 6, 2017, in which the U.S. Fish and Wildlife Service (FWS or the Service) requests public comment to the use of the terms “net conservation gain” and “no net loss” to describe planning goals for the Service’s Endangered Species Act (“ESA”) Compensatory Mitigation Policy. We appreciate the FWS seeking public comments on this policy. However, we have significant concerns with many as-pects of the policy as discussed below. As such, we request the FWS withdraw and revise this policy.

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