Joint Comments on Fish and Wildlife Service Proposed Eagle Permits Rule; Changes in the Regulations Governing Eagle Permitting

Thursday, July 12, 2012

This is a joint public comment written by Defenders of Wildlife (Defenders), Natural Resources Defense Council (NRDC), National Audubon Society, the Sierra Club, The Wilderness Society and 89 Audubon Chapters and State Offices regarding the U.S. Fish and Wildlife Service’s (FWS) proposed Eagle Permit Rule. The comment highlights two fundamental areas of concern in response to the proposed revisions: 1) the proposed changes are not consistent with the legal obligation of FWS to ensure the preservation of eagles under the Bald and Golden Eagle Protection Act (BGEPA), and 2) absent additional analysis, environmental review and public comment, the proposed rulemaking violates National Environmental Policy Act (NEPA) and Administrative Procedure Act (APA) requirements in several ways.