Dear Mr. Ford: The U.S. Chamber of Commerce (Chamber) appreciates the opportunity to comment on the U.S. Fish and Wildlife Service’s (FWS) advance notice of proposed rulemaking for “Eagle Permits; Incidental Take”1 under the Bald and Golden Eagle Protection Act. The Chamber recognizes the importance of eagle conservation and supports common sense permitting that recognizes the use of existing best practices and conservation programs and does not penalize industry with expanded fines or fees or the unwarranted threat of criminal penalties.
Avian conservation is important to businesses operating across industries. As detailed below, businesses have invested (and continue to invest) significant resources to develop and implement conservation practices, including the Avian Protection Plans (APP). Businesses have taken these steps voluntarily, with the goal of minimizing incidental impacts to eagles and other avian species. Encouraging industry to continue to engage in established conservation programs and implement best management practices (BMPs) to satisfy permitting requirements will lead to more immediate regulatory certainty and compliance.