Dear President Bush,
I write in strong opposition to the proposed changes that would weaken Section 7 of the landmark Endangered Species Act.
For more than three decades, this key provision of the ESA has safeguarded imperiled species from the impacts of potentially harmful federal projects.
Key to the success of this provision has been the requirement for interagency consultation between "action agencies" that build dams or highways, issue oil and gas leases or timber cutting contracts, etc., and the "conservation agencies" that have the primary responsibility for protecting endangered species (the U.S. Fish and Wildlife Service and the National Marine Fisheries Service).
The conservation agencies have always had the opportunity and responsibility to take a second look at the projects proposed by the action agencies. As a result of taking that independent look, the conservation agencies have often been able to suggest project modifications that avoid harmful impacts to rare species.
The proposed regulatory changes would eliminate the requirement for an independent review by the conservation agencies. The result will almost certainly mean that both harmful impacts on rare wildlife, and opportunities to avoid those impacts, will be overlooked.
Conservation is not the mission of federal action agencies like the Army Corps of Engineers, the Federal Highway Administration, and others. To make sure that their projects (and the projects of many other federal agencies as well) do not cause needless harm to rare species, the existing requirement for independent review by federal conservation agencies should not be abandoned.