SAF Comments on Proposed ESA Amendments
The Sportsmen’s Alliance Foundation (SAF) recently submitted comments to the U.S. Fish and Wildlife Service and National Marine Fisheries Service (together, Services) on proposed amendments to regulations for administering various provisions of the Endangered Species Act (ESA). SAF supports the Services’ willingness to revise ESA regulations to serve imperiled species and Americans better.
The Need for ESA Reform and Congressional Action
For far too long, ESA administration has strayed from the path Congress created for species protection and recovery. It is time for that to change, and these proposed rules will help make long overdue corrections and they come at a time when Congress is also considering overhauls to the ESA itself. Recently, the House Natural Resources Committee advanced the ESA Amendments Act of 2025 to the House floor, and the House passed a bill that would delist gray wolves in the Lower 48. Clearly, an ESA overhaul is needed to ensure effective species protection, and SAF supports the necessary reforms to better serve species, wildlife managers, and the public.
Targeting the “Blanket Rule” for Threatened Species
Last month, the Services proposed four rules to return ESA regulations to 2019 and 2020 frameworks. SAF provided comments on the two proposals that most directly impact hunters, anglers, and trappers. SAF, specifically, offered comments supporting the proposed rule that would remove the “blanket rule” option for protecting newly listed threatened species pursuant to section 4(d) of the ESA. We also offered comments supporting the proposed rule to add clarity and transparency to the procedures and criteria used for listing, reclassifying, and delisting species and designating critical habitat.
Agencies have used the section 4(d) blanket rule for decades to automatically apply endangered-level protections for newly listed threatened species until a species-specific rule is promulgated for the threatened species. Unfortunately, species-specific rules are rarely made for threatened species, and they are then treated as de facto endangered species. As a result, many management strategies for threatened species are off the table.
Impacts on Gray Wolf Management and State Conservation
The impacts of the blanket rule are seen in places like Minnesota, where we’re fighting to remove gray wolves from the ESA. There, gray wolves are listed as threatened, but because of the blanket rule, they’re treated as endangered. As a result, wolf management in Minnesota is handcuffed and significantly impacting deer, moose, and other species. The proposal to remove the blanket rule will bolster species conservation, allow for more flexible management, and align regulations with Congressional intent.
Ensuring Transparency in Listing and Delisting
SAF also supports the proposed regulations that provide clarity and transparency on how far in the future the Services must consider a species’ status when deciding to list under the ESA, the criteria the Services use in determining to delist a species, and the process used to determine a species’ critical habitat. The proposal also offers clarity to listing and delisting criteria and the critical habitat-designation process while removing redundancies. Ultimately, the proposals bring the Services’ regulations in alignment with the ESA’s text, Congressional intent, and judicial precedent, and will advance the conservation of species.
The Fight to Protect Our Outdoor Heritage
The Sportsmen’s Alliance will continue to monitor the proposals throughout the process and will alert on any further updates.
The legacy of hunting, fishing, and trapping depends on our actions today. Please stand with us or donate to the Sportsmen’s Legal Defense Fund in the fight against those who are working to bully and erode our heritage and traditions.
The Sportsmen’s Alliance guarantees hunting, fishing and trapping for the American sportsman now and forever. We’re there when sportsmen need us most. We are the only organization specifically created to protect the individual hunter, angler, and trapper – no matter the threat. We will never compromise when it comes to defending our way of life in the courts, in the legislatures, in the public square and at the ballot box. We make this promise to the American sportsman: we will never give up and never give in while proudly securing our future against those seeking to destroy our values, beliefs, and traditions. Stay connected to Sportsmen’s Alliance: Online, Facebook, Twitter and Instagram.
