NASF comments on proposed rule to define ‘habitat’ for ESA implementation

Today the National Association of State Foresters submitted official comments to the U.S. Fish and Wildlife Service and the National Marine Fisheries Service regarding their proposed rule to define “habitat” as it pertains to implementation of the Endangered Species Act (ESA).

NASF supports the first and second sentences of the agencies’ proposed habitat definition. However, NASF believes it would be inappropriate for federal agencies to designate “habitat” or “critical habitat” in areas that would have to be substantially modified or altered from their current condition in order to meet the habitat needs of a designated species.

NASF recommends defining habitat as follows: “The physical places that individuals of a species depend upon to carry out one or more life processes. Habitat includes areas where individuals of the species do not presently exist but have the capacity to support such individuals, only where the necessary attributes to support the species presently exist.”

Click the link below to read the comments in full.

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