February 22, 2021

CSF Supports FWS, NOAA Rule to Enhance Forest, Wildlife Health

Article Contact: John Culclasure,

Contact: John Culclasure, Southeastern States Assistant Director

On February 11, the Congressional Sportsmen’s Foundation (CSF) submitted comments in support of the rule proposed by the U.S. Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service that would clarify their consultation requirements under the Endangered Species Act (ESA) with the U.S. Forest Service (USFS) and Bureau of Land Management (BLM).

Specifically, the proposed rule would clarify that consultation does not need to be reinitiated for previously approved land management plans when new information reveals that effects of a plan may, in a manner or extent not previously considered, affect a listed species or critical habitat. The proposed rule would remove ambiguity caused by the Cottonwood Environmental Law Center v. United States Forest Service decision that has been used as the basis for litigation to delay forest management projects across the country. 

CSF’s letter stated, “The revisions would remove ambiguity stemming from Cottonwood for Section 7 ESA consultation at the programmatic level, and we believe the changes are needed to allow the USFS and BLM to implement forest health and wildlife habitat projects without hinderance from litigation or threats of litigation over duplicative consultations.”

CSF supports using active forest management tools to improve wildlife habitat, increase forest resiliency, and improve access and opportunity for sportsmen and women. CSF looks forward to the rule being finalized to improve federal land management.

Studies conducted at both the state and federal level have found that the number of hunters and trappers have been on a generally declining trend over the past several decades. To increase recruitment, retention, and reactivation (R3) of hunters and trappers, which initiative do you think would have the greatest impact?

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