Public Comment on Permits for Incidental Take of Eagles and Eagle Nests

A public comment submitted to the U.S. Fish and Wildlife Service in response to a proposal to create a “general permit” for the incidental take of eagles and eagle nests.

Main Points
  • Allowing permittees to trade excess eagle take authorizations would improve efficiency and better encourage eagle conservation.
  • A market for eagle take authorizations would benefit from monitoring and accountability measures.
  • Extending the market to include transmission lines would further benefit eagle conservation while lowering compliance costs.
Introduction

PERC respectfully submits this comment in response to the U.S. Fish and Wildlife Service’s proposal to create a “general permit” for the incidental take of eagles and eagle nests. While this general permit approach would streamline the permitting process and provide greater certainty for industry and the Service, it doesn’t encourage permittees to reduce impacts to eagles on the margin. According to PERC’s research, however, allowing permitted to sell any authorized take they do not use would provide this incentive. Therefore, PERC urges the Service to consider modifications to the proposed rule that would enable markets to boost conservation of bald and golden eagles.

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