Dear U.S. Fish and Wildlife Service Directors,
The most obvious problem with this Draft Environmental Assessment is that it doesn't consider certain information that is vital to properly and thoroughly analyzing the proposed action at hand: the proposed regulations changes to Section 7 of the Endangered Species Act.
The Draft Assessment unlawfully ignores global warming and climate change's profound impact on threatened and endangered species. Many species already listed as threatened or endangered are being affected by global climate change -- including, but certainly not limited to, the Sonoran pronghorn, piping plover, tidewater goby, grizzly bear, Quino checkerspot butterfly, desert tortoise, and Pitcher's thistle.
In this Draft Environmental Assessment, global warming information -- including recovery plans that explicitly mention global warming as threats -- is ignored entirely. This purposeful blind eye is unquestionably unlawful given the main purpose of the Endangered Species Act: to recover listed species.
The alternatives in the draft document are illegally limited. It is evident from the proposed rule and the Draft Environmental Assessment that the agencies looked only at a preferred alternative of amending the well-established and largely successful Section 7 regulations. The law requires you to take a hard look at the no-action alternative as well as other reasonable alternatives.
The agencies must prepare a Draft EIS to better understand the environmental consequences of their action. The magnitude of federal agency involvement in the Endangered Species Act Section 7 process, and the agencies' own admission that their goal is to greatly reduce these consultations, by itself necessitates the issuance of a draft Environmental Impact Statement and fuller understanding of the impacts of this proposed rule.
The consequences of this proposed rule would be massive, affecting over 1,000 listed species threatened with extinction, and hundreds of millions of acres of imperiled wildlife habitat. The scope of this rule change cannot be overstated in very real practical terms.
I ask that you extend the timeline for comments and issue an Environmental Impact Statement.
Thanks for your consideration.
Comment on FR Doc # N/A
This is comment on Proposed Rule
Interagency Cooperation Under the Endangered Species Act
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