Coalition Request Related to Proposed ESA Compensatory Mitigation Policy

  • Sep 8, 2016
  • Comment Letters

Agency: U.S. Fish and Wildlife Service

Subject: Request for Extension of Comment Period on the U.S. Fish and Wildlife Service Proposed Endangered Species Act Compensatory Mitigation Policy; (Docket No. FWS-HQ-ES-2015-0165)

Coalition members: Full list on NESARC website 

Letter excerpt:

As further explained below, NESARC respectfully requests that FWS extend the comment period by an additional forty-five (45) days, to Thursday, December 1, 2016.

FWS has set a public comment deadline of Monday, October 17, 2016. However, the Proposed Policy includes a variety of complex regulatory and legal principles that demand additional scrutiny. Particularly, the Proposed Policy reflects a significant re-orientation of how FWS will approach the identification, valuation and determination of compensatory mitigation requirements. This raises a number of interrelated issues that require significant study and deliberation in order to provide meaningful public comments. Moreover, such review cannot be undertaken in the limited forty-five (45) day window for comments and information submittals that has been set by FWS. Accordingly, in order to provide for meaningful participation by the public and the development of an adequate administrative record, an extension of the public comment period is warranted to allow the public, states and other federal, state or local agencies to provide meaningful comment on the scope and impacts of the proposed revisions to the Proposed Policy.

Download coalition comment letter

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