By Michael Halpern, Union of Concerned Scientists
The Department of Interior simultaneously announced three majorly flawed proposals that would radically transform how the Endangered Species Act functions and gave the public just 60 days to provide feedback. Yesterday, without providing any reasoning, the department denied a request from UCS to extend the comment period. That means you have six more days to file a comment (Rule 1, Rule 2, Rule 3). This guide from UCS can help you craft an effective comment on one or all of these rules.
Public comments are more than just hyperbole. As part of the official record, they can be used by organizations that wish to challenge the government’s interpretation of a law in court. They are sometimes used by members of Congress conducting oversight over the work of federal agencies. And they can guide future administrations in how they carry out environmental and public health laws.
In a letter requesting a comment period extension, I noted the following:
These proposals could profoundly change the implementation of the Endangered Species Act and the public, including the scientific community, needs sufficient time to better evaluate the impacts of the proposed rule in conjunction with the other two administrative proposals to provide comprehensive and meaningful feedback on it…
Given the critical and comprehensive nature of this proposal, the current timeframe is wholly inadequate and will not allow for thorough public input on these proposed rules and their impact on FWS’s ability to fulfill its mission to conserve, protect and enhance fish, wildlife and plants and their habitats for the continuing benefit of the American people.
When the EPA tried a similar stunt with its proposal to restrict the use of public health science in its work, the agency ultimately agreed to extend the public comment period by more than two months. By this measure, then, the Department of Interior is even worse than Scott Pruitt’s EPA.
Still, we must work with the limited democratic tools we have left. 1500 scientists signed a letter earlier this year that helped inform public understanding of current threats to endangered species by Congress and the Trump administration. Keep that momentum going by submitting a public comment by September 24, 2018. You can also sign on to a more general comment developed by UCS before the deadline.