Summary of the matter addressed in the submission:

The submitter asserts that the US Fish and Wildlife Service has issued administrative directives and memoranda that narrow the meaning of “take” under the ESA. According to the submission, this narrower interpretation excludes from oversight and mitigation requirements the incidental deaths, injuries and habitat destruction of protected species caused by industrial, logging, agricultural, energy and road infrastructure activities in the southwestern United States.

According to the submitter, the Mexican gray wolf is the most threatened canid in North America. Its long-term survival is said to depend on ecological and genetic connectivity between the Sierra Madre Occidental in Mexico and Arizona and New Mexico. The submission claims that unmitigated incidental mortality in US territory threatens an already limited gene pool and undermines binational recovery and reintroduction efforts carried out with Mexican authorities.

Names and citations of the environmental laws in question:

Endangered Species Act:
• Section 9(a)(1)(B)
• Section 10(a)(1)(B)
• Section 4(f)

Submitter(s):

Karla Paulina Hernández Mayor