I. The System is Functioning as Intended

Question: How is the system functioning as intended? Meaning it was always meant to keep the public masses out? So, it’s always been this evil, but it’s just that now the powerful are threatened they are stopping pretending? Why can’t we end it in a year? They need to all go. I cannot stand another day of them in power. Let alone another year. Climate change must be addressed now. We need them out of power by the end of next year

II. Strategy

I strongly oppose the proposed rule that would require economic impacts to be considered in listing and critical habitat decisions. This proposal directly contradicts the plain text, intent, and judicial interpretation of the Endangered Species Act.

Under 16 U.S.C. § 1533(b)(1)(A), listing determinations must be made “solely on the basis of the best scientific and commercial data available.” Courts have consistently affirmed that Congress intentionally prohibited economic considerations during listing decisions (See Tennessee Valley Authority v. Hill, 437 U.S. 153 (1978)). The Supreme Court has repeatedly recognized that Congress intended to “halt and reverse the trend toward species extinction, whatever the cost.”

Reintroducing economic considerations violates statutory requirements and undermines half a century of precedent, making this proposed rule unlawful.

Beyond legality, this rule would create a dangerous and obvious conflict of interest. The industries most responsible for endangering species—logging, mining, fossil fuels, industrial agriculture—would effectively gain veto power over scientific determinations. This contradicts the core purpose of the ESA: to place science and the preservation of ecosystems above short‑term corporate profit.

Requiring economic analysis at this stage invites political manipulation, delays, and litigation while species continue to decline. It transforms the ESA from a science‑based conservation tool into a negotiable permitting program.

I urge the agency to withdraw this proposal entirely. It is contrary to the ESA, unsupported by science, and harmful to the Nation’s biodiversity, public interest, and legal integrity.

I oppose the elimination of the longstanding “blanket 4(d) rule,” which has automatically extended endangered‑level protections to threatened species since 1978.

This rule has been foundational to the ESA’s success. The transition from “threatened” to “endangered” can happen rapidly; without default protections, species may decline irreversibly during the years‑long process of drafting species‑specific rules. Congress created the threatened category to prevent species from reaching the brink of extinction. Removing baseline safeguards defeats that purpose.

Legally, the ESA requires the Secretary to implement protective regulations “as necessary and advisable to provide for the conservation of the species” (16 U.S.C. § 1533(d)). For 45 years, administrations of both parties interpreted this to mean that threatened species generally require robust protections while individualized rules are being developed.

Removing automatic protections for newly listed threatened species creates a dangerous regulatory vacuum where industry can accelerate the very harms that triggered the listing. This is contrary to Congressional intent, which emphasized precaution, not delay.

The proposed change would lead to increased habitat destruction, population loss, and regulatory confusion. It is neither scientifically justified nor administratively efficient.

I urge the agency to withdraw the proposal and retain automatic protections that have been essential to preventing species from sliding into endangered status.

I oppose the proposed revisions to the ESA’s Section 7 consultation process. These changes would narrow definitions of “effects,” ignore cumulative and indirect impacts, and dramatically lower the obligations of federal agencies to avoid jeopardizing listed species.

Section 7(a)(2) imposes an affirmative, non‑discretionary duty on federal agencies to ensure their actions are not likely to “jeopardize the continued existence” of listed species or “destroy or adversely modify” critical habitat. Courts have held that this requires a comprehensive, science‑based evaluation of direct, indirect, and cumulative impacts (see Karuk Tribe of Cal. v. U.S. Forest Serv., 681 F.3d 1006 (9th Cir. 2012)).

The proposed rule attempts to redefine away large categories of harm by excluding cumulative, long‑term, or “uncertain” impacts — which in ecology are often the most significant drivers of decline.

This is scientifically indefensible. Species are not harmed only by sudden catastrophic events; they decline through chronic habitat fragmentation, pollution, noise, climate‑driven stressors, and repeated small administrative decisions that add up to irreversible loss.

By raising the evidentiary threshold and weakening the definition of adverse modification, the rule would allow agencies to green‑light destructive federal actions — pipelines, highways, logging, mining — with virtually no accountability.

The ESA’s effectiveness depends on Section 7. Gutting consultations effectively guts the Act.

I urge the agency to withdraw this proposal.

I strongly oppose this proposed rule, which would allow industries to exert disproportionate influence over critical habitat designations and require the agency to exclude habitat whenever economic claims outweigh ecological needs.

This flips the ESA on its head. Critical habitat is defined under 16 U.S.C. § 1532(5) as areas “essential to the conservation of the species.” Congress did not authorize industry veto power, nor did it require the agency to prioritize economic concerns over ecological necessity.

The proposal would require the agency to exclude habitat unless it can prove the exclusion would lead directly to extinction — an impossibly high standard that contradicts both science and law. Recovery, not mere survival, is the legal standard of the ESA. Species need habitat to expand, recolonize, adapt to climate change, and achieve viable population levels.

The rule also undermines the precautionary principle by dismissing unoccupied habitat, even when essential for climate resilience, migration corridors, or recovery planning. Courts have upheld the inclusion of unoccupied habitat as long as it is essential for conservation.

Giving regulated industries the ability to demand exclusions invites political pressure, manipulation of economic projections, and decisions contrary to both the statute and the best available science.

I urge the agency to withdraw this rule and maintain science‑based habitat protections.

Why We Need a Media Revolution

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This Moment is Symbolic

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