Nov 23, 2021 IPAA Comment Letter on Critical Habitat Definition
The Independent Petroleum Association of America (IPAA) appreciates the opportunity to comment on the U.S. Fish and Wildlife proposal to rescind the final rule titled “Endangered and Threatened Wildlife and Plants; Regulations for Designating Critical Habitat” that published on December 18, 2020, and became effective January 19, 2021 (“the Final Rule”). IPAA does not support the rescission and is supportive of the Service’s previous efforts to clarify language and return the Endangered Species Act (ESA) back to the original intent of the law. Unfortunately, the ESA has been used all too frequently as a tool for litigation and a vehicle to stall important development projects for years and even decades. IPAA supported the Service’s previous rule as it led to safeguard species conservation while also clarifying criteria for consistent critical habitat designation.