On September 24, 2018, WLF filed formal comments with the Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) (collectively, “Services”), applauding the Services’ efforts to provide clarity in the conservation process and urging them to adopt a standard requiring economic impact statements for each species-listing decision. WLF’s comments note that critical habitat designations, which require economic impact analyses, will be more predictable and consistent if the Services consider costs and benefits at the listing stage. This approach would emphasize the economic realities of regulation, counteracting the efforts of special interest groups that use the Endangered Species Act to push regulations based on biases without regard to the potential impact on landowners.
