State Foresters Disappointed about USFWS Revisions to Petition Process

The National Association of State Foresters (NASF) submitted comments this week in response to the U.S. Fish and Wildlife Service (USFWS) revisions to the proposed rule for those who want to file petitions for listing under the Endangered Species Act (ESA) (81 Fed. Reg. 23448). Learn more about the revisions at

In July 2015, NASF submitted comments during the initial USFWS comment period and State Foresters are disappointed to see that the most critical and beneficial aspect of this proposed revision is being scaled back.  

NASF members supported the initial proposal as a way to enhance the role of state government expertise in the petition process and foster collaboration among all stakeholder groups with an interest in wildlife conservation.  The original proposal would have benefitted species conservation and strengthened cooperation. However, the changes released to this proposal by USFWS last month greatly diminish the role of states in the petition process. 

"This revision removes the element of cooperation that was being fostered through the original proposal. The tactic of serially petitioning and litigating the USFWS is not representative of the approach to species conservation supported by most stakeholders in the wildlife community.  Anything the USFWS can do to foster increased dialogue between petitioners, other interest groups and state agencies engaged in wildlife conservation will ultimately be for the benefit of the species. Our efforts are strengthened the more we work together, cooperate, and share expertise," Wisconsin State Forester and NASF President Paul DeLong said in the written comments.

State Foresters are disappointed with the changes made to these proposed revisions regarding the role of states in the petition process. We request that the USFWS rescinds these changes and once again requires petitioners to coordinate with states through the gathering of pertinent information. To learn more, read the recent NASF policy statement ​Improving the Effectiveness of The Endangered Species Act.

View NASF's comments.

Contact NASF Policy Director Gary Schiff.


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