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LETTER: Endangered and Threatened Wildlife and Plants; Endangered Species Act Compensatory Mitigation Policy

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September 27, 2016

Dan Ashe, Director
U.S. Fish and Wildlife Service
U.S. Department of the Interior
1849 C Street, N.W., Room 3331
Washington, D.C. 20240

Re: Comment period extension request – 81 FR 61031, Endangered and Threatened Wildlife and Plants; Endangered Species Act Compensatory Mitigation Policy

Dear Director Ashe:

The Western Governors’ Association (WGA) represents Governors from 19 western states and three U.S.-flag islands. The Association is an instrument of the Governors for bipartisan policy development, information sharing and collective action on issues of critical importance to the western United States. Western states play an integral role in species conservation and partner with the U.S. Fish and Wildlife Service (Service) on conservation efforts. States represented by WGA may be profoundly affected by decisions made by the Service and have a significant interest in how compensatory mitigation under the Endangered Species Act (ESA) is conducted.

The Governors’ partnership with the Service throughout the Western Governors’ Species Conservation and Endangered Species Act Initiative is demonstrative of our states’ ardent interest in improving the efficacy of the ESA and enhancing coordination with state wildlife agencies.

The proposed policy, Endangered and Threatened Wildlife and Plants; Endangered Species Act Compensatory Mitigation Policy (81 FR 61031, September 2, 2016) (Proposal) will impact western states and state species conservation. The Proposal will also affect project planning and development in the West. The current public comment timeframe is inadequate and is insufficient to accommodate thoughtful analysis of the Proposal and its impact on western states.

Given the importance and complexity of the Proposal for western states, we request a comment period extension of at least 45 days. Thank you for your consideration.

Respectfully,

Steve Bullock
Governor of Montana
Chairman, WGA

Dennis Daugaard
Governor of South Dakota
Vice Chair, WGA

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