U.S. Fish and Wildlife Service

MS: PRB/3W

5275 Leesburg Pike

Falls Church, VA 22041-3803

Ref: Docket No. FWS-HQ-ES-2025-0034

Rescinding the Definition of Harm under the Endangered Species Act

Dear Administrator,

My name is XX and I am writing to you as a geologist with a Master’s, currently working in environmental remediation. I am writing to you with deep concern over the proposed redefinition of “Harm” in the statutory definition of “Take” in the Endangered Species Act (ESA) as executed by the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS).

I firmly disagree with the stance that the FWS and NMFS did not correctly interpret the statute regarding harm in the ESA. As a scientist who has studied ecosystems and has significant experience in dealing with environmental contamination, I can definitively assure you that harm to habitat and ecosystems fulfills the definition of harm to a protected species. To poison the waterway where a silver chub lives is to poison a silver chub. To destroy the nest of a golden eagle can lead to the deaths of fledglings. I assert that the legally correct definition of harm to an animal includes harm to its habitat, livelihood, food source, and ability to raise young. There is no excuse to rescind the regulatory definition of “harm”.

In no capacity has the FWS or NMFS overextended their reach in their execution of the ESA to include harm as habitat modification or degradation. To rescind the definition of harm under the statutory definition of “take” is to disregard the original intent of the ESA to preserve the unique wildlife under threat in the United States.

I urge with all my heart to dismiss the proposed revision, as it does not reflect an honest interpretation of the statutory text of the ESA and will cause uncorrectable damage to our precious wildlife.