Coalition Comments on Habitat Conservation Planning Handbook Aug 29, 2016 Comment Letters Agency: U.S. Fish and Wildlife Subject: NESARC Comments on the Joint U.S. Fish and Wildlife Service and National Marine Fisheries Service Habitat Conservation Planning Handbook Coalition members: Full list on NESARC website Letter excerpt: The Services state that the goal of revising the Handbook is to help streamline and improve the efficiency of the HCP program. To accomplish this goal, the Services attempt to address stakeholder concerns that the HCP and incidental take development and approval processes are inefficient due to: the length of time and costs associated with HCP development, the complexity of negotiations, implementation expense, lack of certainty, and lack of readily apparent benefits associated with the HCP program. While well-intentioned and providing some measurement of improvement in certain areas, the Services’ present revisions in the Draft Handbook do not fully address the ambiguities, complexities and lack of certainty that the Services have acknowledged as persisting in the process for developing and approving HCPs. In particular, the Services’ proposed revisions appear to exacerbate previously identified inefficiencies and impose more burdensome documentation and data requirements. Moreover, and of particular concern, the Draft Handbook appears to put in place administrative measures that raise the threshold for HCP approval and erode the No Surprises commitment that has been so fundamental in encouraging voluntary development of HCPs. Without further improvements, NESARC expects that the Draft Handbook will act as a disincentive for participation in habitat conservation planning. Download coalition letter
