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Natural Resource Conservation

Incorporating Endangered Species Act Section 7(a)(1) Into Integrated Natural Resource Management Plans


Lucas Cooksey, Project Director, Texas A&M - Natural Resources Institute:


This technical session will explore the Law, Regulations and Guidance currently in existence in relation to ESA Section 7(a)(1) and aid in INRMP development for the DoD Services regarding management actions contributing to ESA Section 7(a)(1) conservation. Within existing DoD guidance documents, there is little or no mention of Endangered Species Act (ESA) Section 7(a)(1). This should not be too surprising; as before the Sikes Act Improvement Act of 1997 was enacted, installations with listed species developed Endangered Species Management Plans that would address ESA Section 7(a)(1). After the enactment of the Sikes Act Improvement Act (SAIA), it was generally felt that Integrated Natural Resource Management Plans (INRMP) would satisfy the requirements of ESA Section 7(a)(1). This is not to say that INRMPs were then or are now as good as they could be if more emphasis were to be given to Section 7(a)(1) within them, and especially, the advantages of acting in advance of any ESA Section 7(a)(2) obligation.

There should be no doubt that after the enactment of the SAIA, INRMPs are intended to encompass the entire range of species and habitats extant on DoD installations, not just listed species. Most installation natural resources managers understand and have embraced this requirement however, despite activities being conducted that meet the ESA Section 7(a)(1) definition, installations are not sufficiently recognized for conservation attributed to these activities in 7(a)(2) consultation. Additionally, installation’s do not uniformly use their INRMPs and engagement with USFWS strategically to maximize both their conservation effectiveness and their value in smoothing 7(a)(2) consultations and reducing add-on consultation obligations. Exploring ways to deliberately address ESA Section 7(a)(1) within an INRMP will ensure all management actions are clearly identified and receive due consideration in the ESA Section 7(a)(2) consultation process.

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