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SCI Submits Slew of Federal Comments on ESA, Refuge System

SCI has been busy this week submitting comments to the U.S. Fish and Wildlife Service regarding the Endangered Species Act and National Wildlife Refuge System.

First, SCI opposed a proposal to reinstate the “blanket rule” for threatened species.  The blanket rule imposes all the same prohibitions (on take, import, etc.) as for endangered species.  SCI explained, with specific reference to legislative history of the ESA, how this proposal contradicts Congressional intent in creating two listing categories and requiring the Service to adopt special regulations for threatened species.  SCI used two examples to demonstrate how application of the blanket rule can have detrimental impacts and disincentivize the conservation of foreign species by creating barriers to import.

Second, SCI largely opposed a proposal to remove any mention of economic or other impacts from listing rules, and to revise the regulation identifying grounds for removing a species from the ESA lists.  The proposed rule rolls back changes made in the prior Administration.  SCI objected to the proposal because the existing regulations make clear, first, that ESA listings can have negative impacts as well as positive ones, and second, that the ESA’s goal is to delist species as soon as possible. 

Last, SCI submitted comments on the proposed 2023 Hunt Fish Rule, which proposes to expand hunting on three National Wildlife Refuges (3,000 acres total).  SCI supports that expansion.  However, SCI pointed out that the Service could and should do more to open and expand hunting on Refuges, especially since conservation groups have submitted lists of potential openings that were not addressed in the proposed rule.  Further, SCI’s comments objected to a proposal to phase out the use of lead ammunition and tackle on eight refuges, which was originally announced in last year’s rule.  The comments criticize these lead restrictions for being unnecessary, as no scientific evidence demonstrates any negative impacts from use of lead ammunition or tackle on these Refuges.  SCI also objected because lead restrictions are likely to reduce hunter participation and access, with detrimental consequences for wildlife management and conservation funding.

The Service has hundreds of thousands of comments on these three proposals, and will need to review and respond to those comments in finalizing the regulations.