Comment Opposing Changes Proposed by Fish & Wildlife Service to Endangered Species Act Regulations

ARTBA sent a letter to the Director of the U.S. Fish and Wildlife Service regarding proposed changes to Endangered Species Act Regulations stating that:

• ARTBA members need transparency about how critical habitat decisions are made.
• In designating critical habitat, the Service cannot rely on broad global-scale events that have no nexus or endpoint.
• ARTBA members face significant economic impacts from regulatory uncertainty.
• The Service should transparently disclose how it calculates mitigation and should not impose unnecessary additional measures.