[Federal Register Volume 86, Number 189 (Monday, October 4, 2021)]
[Rules and Regulations]
[Pages 54642-54656]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-21473]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF THE INTERIOR
Fish and Wildlife Service
50 CFR Part 10
[Docket No. FWS-HQ-MB-2018-0090; FF09M22000-212-FXMB1231099BPP0]
RIN 1018-BD76
Regulations Governing Take of Migratory Birds; Revocation of
Provisions
AGENCY: Fish and Wildlife Service, Interior.
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: On January 7, 2021, we, the U.S. Fish and Wildlife Service
(we, the Service, or USFWS), published a final rule (January 7 rule)
defining the scope of the Migratory Bird Treaty Act (MBTA) as it
applies to conduct resulting in the injury or death of migratory birds
protected by the MBTA. We now revoke that rule for the reasons set
forth below. The immediate effect of this final rule is to return to
implementing the MBTA as prohibiting incidental take and applying
enforcement discretion, consistent with judicial precedent and
longstanding agency practice prior to 2017.
DATES: This rule is effective December 3, 2021.
FOR FURTHER INFORMATION CONTACT: Jerome Ford, Assistant Director,
Migratory Birds, at 202-208-1050.
SUPPLEMENTARY INFORMATION: On January 7, 2021, we published a final
rule defining the scope of the MBTA (16 U.S.C. 703 et seq.) as it
applies to conduct resulting in the injury or death of migratory birds
protected by the MBTA (86 FR 1134) (hereafter referred to as the
``January 7 rule''). The January 7 rule codified an interpretation of
the MBTA set forth in a 2017 legal opinion of the Solicitor of the
Department of the Interior, Solicitor's Opinion M-37050 (also referred
to as the Jorjani Opinion), which concluded that the MBTA does not
prohibit incidental take.
As initially published, the January 7 rule was to become effective
30 days later, on February 8, 2021. However, on February 4, 2021, USFWS
submitted a final rule to the Federal Register correcting the January 7
rule's effective date to March 8, 2021, to conform with its status as a
``major rule'' under the Congressional Review Act, which requires a
minimum effective date period of 60 days, see 5 U.S.C. 801(a)(3) and
804(2). The final rule extending the effective date of the January 7
final rule itself became effective when it was made available for
public inspection in the reading room of the Office of the Federal
Register on February 5, 2021, and was published in the Federal Register
on February 9, 2021 (86 FR 8715). In that document, we also sought
public comment to inform our review of the January 7 rule and to
determine whether further extension of the effective date was
necessary.
After further review, we decided not to extend the effective date
of the January 7 rule beyond March 8. We acknowledged that the January
7 rule would remain in effect for some period of time even if it is
ultimately determined, after notice and comment, that it should be
revoked. But rather than extending the effective date again, we
determined that the most transparent and efficient path forward was
instead to immediately propose to revoke the January 7 rule. The
proposed rule provided the public with notice of our intent to revoke
the January 7 rule, subject to our final decision after consideration
of public comments.
We have undertaken further review of the January 7 rule and
considered public comments on our proposed revocation rule and
determine that the January 7 rule does not reflect the best reading of
the MBTA's text, purpose, and history. It is also inconsistent with the
majority of relevant court decisions addressing the issue, including
the decision of the District Court for the Southern District of New
York on August 11, 2020 that expressly rejected the rationale offered
in the rule. The January 7 rule's reading of the MBTA also raises
serious concerns with Canada, a United States' treaty partner, and for
the migratory bird resources protected by the MBTA and underlying
treaties. Accordingly, we revoke the January 7 rule and remove the
regulation codifying the interpretation set forth in the January 7 rule
at 50 CFR 10.14.
At this time, we have not proposed replacement language for the
Code of Federal Regulations. This rulemaking simply removes the current
regulatory language. A Director's Order clarifying our current
enforcement position was issued at the time of this final rule's
publication and will come into effect on the effective date of this
final rule (see DATES). We will introduce new policies in the future,
including a proposed regulation codifying an interpretation of the MBTA
that prohibits incidental take and potentially a regulatory framework
for the issuance of permits to authorize incidental take. Concurrent
with this final rule, we have also published an advance notice of
proposed rulemaking requesting public input on potential alternatives
for authorizing incidental take of migratory birds and a Director's
Order clarifying our current enforcement position. These new policies
and regulatory actions will fully implement the new National
Environmental Policy Act (NEPA) Record of Decision (ROD) associated
with this revocation rule, which is available at https://www.fws.gov/regulations/mbta/resources.
The MBTA statutory provisions at issue in the January 7 rule have
been the subject of repeated litigation and diametrically opposed
opinions of the Solicitors of the Department of the Interior. The
longstanding historical agency practice confirmed in the earlier
Solicitor M-Opinion, M-37041, and upheld by most reviewing courts, had
been that the MBTA prohibits the incidental take of migratory birds
(subject to certain legal constraints). The January 7 rule reversed
several decades of past agency practice and interpreted the scope of
the MBTA to exclude any prohibition on the incidental take of migratory
birds. In so doing, the January 7 rule codified Solicitor's Opinion M-
37050, which itself had been vacated by the United States District
Court for the Southern District of New York. This interpretation
focused on the language of section 2 of the MBTA, which, in relevant
part, makes it ``unlawful at any time, by any means, or in any manner,
to pursue, hunt, take, capture, kill'' migratory birds or attempt to do
the same. 16 U.S.C. 703(a). Solicitor's Opinion M-37050 and the January
7 rule argued that the prohibited terms listed in section 2 all refer
to conduct directed at migratory birds, and that the broad preceding
language, ``by any means, or in any manner,'' simply covers all
potential methods and means of performing actions directed at
[[Page 54643]]
migratory birds and does not extend coverage to actions that
incidentally take or kill migratory birds.
As noted above, on August 11, 2020, a court rejected the
interpretation set forth in Solicitor's Opinion M-37050 as contrary to
the MBTA and vacated that opinion. Natural Res. Def. Council v. U.S.
Dep't of the Interior, 478 F. Supp. 3d 469 (S.D.N.Y. 2020) (``NRDC'').
In late January 2021, two new lawsuits were filed that challenge the
January 7 rule. Nat'l Audubon Soc'y v. U.S. Fish & Wildlife Serv.,
1:21-cv-00448 (S.D.N.Y. filed Jan. 19, 2021); State of New York v. U.S.
Dep't of the Interior, 1:21-cv-00452 (S.D.N.Y. filed Jan. 19, 2021). At
the time the January 7 rule was published, the United States had filed
a notice of appeal of the NRDC decision in the U.S. Court of Appeals
for the Second Circuit. Since that time, the United States filed a
stipulation to dismiss that appeal on February 25, 2021, and the Deputy
Solicitor permanently withdrew M-37050 on March 8, 2021.
The District Court's decision in NRDC expressly rejected the basis
for the January 7 rule's conclusion that the statute does not prohibit
incidental take. In particular, the court reasoned that the plain
language of the MBTA's prohibition on killing protected migratory bird
species ``at any time, by any means, and in any manner'' shows that the
MBTA prohibits incidental killing. See 478 F. Supp. 3d at 481. Thus,
the statute is not limited to actions directed at migratory birds as
set forth in the January 7 rule. After closely examining the court's
holding, we are persuaded that it advances the better reading of the
statute, including that the most natural reading of ``kill'' is that it
also prohibits incidental killing.
The interpretation contained in the January 7 rule relies heavily
on United States v. CITGO Petroleum Corp., 801 F.3d 477 (5th Cir. 2015)
(CITGO). The Fifth Circuit is the only Circuit Court of Appeals to
expressly state that the MBTA does not prohibit incidental take. In
CITGO, the Fifth Circuit held that the term ``take'' in the MBTA does
not include incidental taking because ``take'' at the time the MBTA was
enacted in 1918 referred in common law to ``[reducing] animals, by
killing or capturing, to human control'' and accordingly could not
apply to accidental or incidental take. Id. at 489 (following Babbitt
v. Sweet Home Chapter Cmtys. for a Great Or., 515 U.S. 687, 717 (1995)
(Scalia J., dissenting) (Sweet Home)). While we do not agree with the
CITGO court's interpretation of the term ``take'' under the MBTA, we
further note that CITGO does not provide legal precedent for construing
``kill'' narrowly. The CITGO court's analysis is limited by its terms
to addressing the meaning of the term ``take'' under the MBTA; thus,
any analysis of the meaning of the term ``kill'' was not part of the
court's holding.
Moreover, as discussed below and even though it was dicta, we also
disagree with the CITGO court's analysis of the term ``kill.''
Although the CITGO court's holding was limited to interpreting
``take,'' the court opined in dicta that the term ``kill'' is limited
to intentional acts aimed at migratory birds in the same manner as
``take.'' See 801 F.3d at 489 n.10. However, the court based this
conclusion on two questionable premises.
First, the court stated that ``kill'' has little if any independent
meaning outside of the surrounding prohibitory terms ``pursue,''
``hunt,'' ``capture,'' and ``take,'' analogizing the list of prohibited
acts to those of two other environmental statutes--the Endangered
Species Act (ESA) (16 U.S.C. 1531 et seq.) and the Migratory Bird
Conservation Act (16 U.S.C. 715 et seq.). See id. The obvious problem
with this argument is that it effectively reads the term ``kill'' out
of the statute; in other words, the CITGO court's reasoning renders
``kill'' superfluous to the other terms mentioned, thus violating the
rule against surplusage. See, e.g., Corley v. United States, 556 U.S.
303, 314 (2009).
Second, employing the noscitur a sociis canon of statutory
construction (which provides that the meaning of an ambiguous word
should be determined by considering its context within the words it is
associated with), the Fifth Circuit argued that because the surrounding
terms apply to ``deliberate acts that effect bird deaths,'' then
``kill'' must also. See 801 F.3d at 489 n.10. The January 7 rule also
relied heavily on this canon to argue that both ``take'' and ``kill''
must be read as deliberate acts in concert with the other referenced
terms. Upon closer inspection though, the only terms that clearly and
unambiguously refer to deliberate acts are ``hunt'' and ``pursue.''
Both the CITGO court and the January 7 final rule erroneously
determined that ``capture'' can also only be interpreted as a
deliberate act. This is not so. There are many examples of
unintentional or incidental capture, such as incidental capture in
traps intended for animals other than birds or in netting designed to
prevent swallows nesting under bridges. Thus, the CITGO court's primary
argument that ``kill'' only applies to ``deliberate actions'' rests on
the fact that just two of the five prohibited actions unambiguously
describe deliberate acts. The fact that most of the prohibited terms
can be read to encompass actions that are not deliberate in nature is a
strong indication that Congress did not intend those terms to narrowly
apply only to direct actions.
The NRDC court similarly rejected the January 7 rule's
interpretation of the term ``kill'' and its meaning within the context
of the list of actions prohibited by the MBTA. The court noted the
broad, expansive language of section 2 prohibiting hunting, pursuit,
capture, taking, and killing of migratory birds ``by any means or in
any manner.'' 478 F. Supp. 3d at 482. The court reasoned that the plain
meaning of this language can only be construed to mean that activities
that result in the death of a migratory bird are a violation
``irrespective of whether those activities are specifically directed at
wildlife.'' Id. The court also noted that the Sweet Home decision
relied upon by the CITGO court and the January 7 rule actually counsels
in favor of a broad reading of the term ``kill,'' even assuming Justice
Scalia accurately defined the term ``take'' in his dissent. The Sweet
Home case dealt specifically with the definition of ``take'' under the
ESA, which included the terms ``harm'' and ``kill.'' The majority in
Sweet Home was critical of the consequences of limiting liability under
the ESA to ``affirmative conduct intentionally directed against a
particular animal or animals,'' reasoning that knowledge of the
consequences of an act are sufficient to infer liability, including
typical incidental take scenarios. Id. at 481-82.
The NRDC court went on to criticize the use of the noscitur a
sociis canon in Solicitor's Opinion M-37050 (a use repeated in the
January 7 rule). The court reasoned that the term ``kill'' is broad and
can apply to both intentional, unintentional, and incidental conduct.
The court faulted the Solicitor's narrow view of the term and disagreed
that the surrounding terms required that narrow reading. To the
contrary, the court found the term ``kill'' to be broad and not at all
ambiguous, pointedly noting that proper use of the noscitur canon is
confined to interpreting ambiguous statutory language. Moreover, use of
the noscitur canon deprives ``kill'' of any independent meaning, which
runs headlong into the canon against surplusage as noted above. The
court did not agree that an example provided by the government
demonstrated that ``kill'' had independent meaning from ``take'' under
the interpretation espoused by Solicitor's Opinion M-37050. By analogy,
the court referenced
[[Page 54644]]
the Supreme Court's rejection of the dissent's use of the noscitur
canon in Sweet Home, which similarly gave the term ``harm'' the same
essential function as the surrounding terms used in the definition of
``take'' under the ESA, denying it independent meaning. See id. at 484.
The CITGO court, M-37050, and the January 7 rule also cited
potential constitutional concerns in rejecting an interpretation of the
MBTA that prohibits incidental take--specifically that this
interpretation results in implementing the MBTA in a vague and
overbroad manner thus violating the constitutional right to due
process. Although the NRDC court did not address these concerns because
it found the language of the MBTA unambiguous in the context of its
application to incidental take, these concerns also do not counsel in
favor of rejecting that interpretation even if the relevant language is
considered ambiguous. The constitutional concerns cited in the January
7 rule can be addressed simply by noting that the Act's reach within
the context of incidental take is limited by applying the standard
legal tools of proximate causation and foreseeability--as explained by
the Tenth Circuit in United States v. Apollo Energies, 611 F.3d 679
(10th Cir. 2010) and in M-37041--and by adopting policies and
regulations that eliminate potential prosecutorial overreach and absurd
results. Upon revocation of this rule, we issued a Director's Order
clarifying our current enforcement position and will consider
developing a regulatory authorization framework, as explained below.
These policies will eliminate any potential constitutional concerns by
providing the public with adequate notice of the scope of potential
liability under the MBTA and how any potential violations may be
avoided or authorized.
In sum, after further review of the January 7 rule and the CITGO
and NRDC decisions, along with the language of the statute, we now
conclude that the interpretation of the MBTA set forth in the January 7
rule and Solicitor's Opinion M-37050, which provided the basis for that
interpretation, is not the construction that best accords with the
text, purposes, and history of the MBTA. It simply cannot be squared
with the NRDC court's holding that the MBTA's plain language
encompasses the incidental killing of migratory birds. Even if the NRDC
court's plain-language analysis were incorrect, the operative language
of the MBTA is at minimum ambiguous, thus USFWS has discretion to
implement that language in a manner consistent with the conservation
purposes of the statute and its underlying Conventions that avoids any
potential constitutional concerns. Reference to case law in general or
legislative history can be interpreted to bolster either interpretation
as demonstrated by the relevant analysis in the January 7 rule versus
that of the initial Solicitor's Opinion, M-37041, thus is of limited
assistance if the relevant language is indeed ambiguous. In any case,
the Service certainly has discretion to revoke the January 7 rule given
the legal infirmities raised by the NRDC court and the rule's reliance
on the CITGO decision.
To the extent that the primary policy justifications for the
January 7 rule were resolving uncertainty and increasing transparency
through rulemaking, we do not consider these concerns to outweigh the
legal infirmities of the January 7 rule or the conservation purposes of
the statute and its underlying Conventions. Interpreting the statute to
exclude incidental take is not the reading that best advances these
purposes or provides the most natural reading of section 2, which is
underscored by the following additional reasons for revoking the
current regulation.
First, the January 7 rule is undermined by the 2002 legislation
authorizing military-readiness activities that incidentally take or
kill migratory birds. In that legislation, Congress temporarily
exempted ``incidental taking'' caused by military-readiness activities
from the prohibitions of the MBTA; required the Secretary of Defense to
identify, minimize, and mitigate the adverse effect of military-
readiness activities on migratory birds; and directed USFWS to issue
regulations under the MBTA creating a permanent exemption for military-
readiness activities. Bob Stump National Defense Authorization Act for
Fiscal Year 2003, Public Law 107-314, Div. A, Title III, section 315
(2002), 116 Stat. 2509 (Stump Act). This legislation was enacted in
response to a court ruling that had enjoined military training that
incidentally killed migratory birds. Ctr. for Biological Diversity v.
Pirie, 191 F. Supp. 2d 161 and 201 F. Supp. 2d 113 (D.D.C. 2002),
vacated on other grounds sub nom. Ctr. for Biological Diversity v.
England, 2003 U.S. App. Lexis 1110 (D.C. Cir. Jan. 23, 2003). Notably,
Congress did not amend the MBTA to define the terms ``take'' or
``kill.'' Instead, Congress itself uses the term ``incidental take''
and provides that the MBTA ``shall not apply'' to such take by the
Armed Forces during ``military-readiness activities.'' Moreover,
Congress limited the exemption only to military-readiness activities,
i.e., training and operations related to combat and the testing of
equipment for combat use. It expressly excluded routine military-
support functions and the ``operation of industrial activities'' from
the exemption afforded by the 2002 legislation, leaving such non-
combat-related activities fully subject to the prohibitions of the Act.
Even then, the military-readiness incidental take carve-out was only
temporarily effectuated through the statute itself. Congress further
directed the Department of the Interior (DOI or the Department) ``to
prescribe regulations to exempt the Armed Forces for the incidental
taking of migratory birds during military readiness activities.''
This would be an odd manner in which to proceed to address the
issue raised by the Pirie case if Congress' governing understanding at
the time was that incidental take of any kind was not covered by the
Act. Congress simply could have amended the MBTA to clarify that
incidental take is not prohibited by the statute or, at the least, that
take incidental to military-readiness activities is not prohibited.
Instead, Congress limited its amendment to exempting incidental take
only by military-readiness activities, expressly excluded other
military activities from the exemption, and further directed DOI to
issue regulations delineating the scope of the military-readiness
carve-out from the incidental-take prohibitions of the Act. All of
these factors indicate that Congress understood that the MBTA's take
and kill prohibitions included what Congress itself termed ``incidental
take.''
In arguing that Congress's authorization of incidental take during
military-readiness activities did not authorize enforcement of
incidental take in other contexts, the January 7 rule cites the CITGO
court's conclusion that a ``single carve-out from the law cannot mean
that the entire coverage of the MBTA was implicitly and hugely
expanded.'' CITGO, 801 F.3d at 491. It is true that the Stump Act did
not, by its terms, authorize enforcement of incidental take in other
contexts. It clearly could not do anything of the sort, based on its
narrow application to military-readiness activities. Rather, the
logical explanation is that Congress considered that the MBTA already
prohibited incidental take (particularly given USFWS's enforcement of
incidental take violations over the prior three decades) and there was
no comprehensive regulatory mechanism available to authorize that take.
Thus, it was necessary to temporarily exempt incidental take pursuant
to military-readiness activities to address the Pirie
[[Page 54645]]
case and direct USFWS to create a permanent exemption. This conclusion
is supported by the fact that Congress specifically stated in the Stump
Act that the exemption did not apply to certain military activities
that do not meet the definition of military readiness, including
operation of industrial activities and routine military-support
functions.
On closer inspection, the CITGO court's analysis of the purposes
behind enactment of the military-readiness exemption is circular.
Assuming the military-readiness exemption is necessary because the MBTA
otherwise prohibits incidental take only represents an implicit and
huge expansion of coverage under the MBTA if it is assumed that the
statute did not already prohibit incidental take up to that point. But
Congress would have had no need to enact the exemption if the MBTA did
not--both on its terms and in Congress's understanding--prohibit
incidental take. The adoption of a provision to exempt incidental take
in one specific instance is merely a narrowly tailored exception to the
general rule and provides clear evidence of what Congress understood
the MBTA to prohibit.
Second, further consideration of concerns expressed by one of our
treaty partners counsels in favor of revoking the January 7 rule. The
MBTA implements four bilateral migratory bird Conventions with Canada,
Mexico, Russia, and Japan. See 16 U.S.C. 703-705, 712. The Government
of Canada communicated its concerns with the January 7 rule both during
and after the rulemaking process, including providing comments on the
environmental impact statement (EIS) associated with the rule.
After the public notice and comment period had closed, Canada's
Minister of Environment and Climate Change summarized the Government of
Canada's concerns in a public statement issued on December 18, 2020
(https://www.canada.ca/en/environment-climate-change/news/2020/12/minister-wilkinson-expresses-concern-over-proposed-regulatory-changes-to-the-united-states-migratory-bird-treaty-act.html). Minister
Wilkinson voiced the Government of Canada's concern regarding ``the
potential negative impacts to our shared migratory bird species'' of
allowing the incidental take of migratory birds under the MBTA rule and
``the lack of quantitative analysis to inform the decision.'' He noted
that the ``Government of Canada's interpretation of the proposed
changes . . . is that they are not consistent with the objectives of
the Convention for the Protection of Migratory Birds in the United
States and Canada.'' Additionally, in its public comments on the draft
EIS for the MBTA rule, Canada stated that it believes the rule ``is
inconsistent with previous understandings between Canada and the United
States (U.S.), and is inconsistent with the long-standing protections
that have been afforded to non-targeted birds under the Convention for
the Protection of Migratory Birds in the United States and Canada . . .
as agreed upon by Canada and the U.S. through Article I. The removal of
such protections will result in further unmitigated risks to vulnerable
bird populations protected under the Convention.'' After further
consideration, we have similar concerns to those of our treaty partner,
Canada.
The protections for ``non-targeted birds'' noted by the Canadian
Minister are part and parcel of the Canada Convention, as amended by
the Protocol between the United States and Canada Amending the 1916
Convention for the Protection of Migratory Birds in Canada and the
United States, which protects not only game birds hunted and trapped
for sport and food, but also nongame birds and insectivorous birds. For
instance, the preamble to the Convention declares ``saving from
indiscriminate slaughter and of insuring the preservation of such
migratory birds as are either useful to man or are harmless'' as its
very purpose and declares that ``many of these species are . . . in
danger of extermination through lack of adequate protection during the
nesting season or while on their way to and from their breeding
grounds.'' Convention between the United States and Great Britain (on
behalf of Canada) for the Protection of Migratory Birds, 39 Stat. 1702
(Aug. 16, 1916). Thus, whether one argues that the language of section
2 of the MBTA plainly prohibits incidental killing of migratory birds
or is ambiguous in that regard, an interpretation that excludes
incidental killing is difficult to square with the express conservation
purposes of the Canada Convention. Moreover, until recently there had
been a longstanding ``mutually held interpretation'' between the two
treaty partners that regulating incidental take is consistent with the
underlying Convention, as stated in an exchange of Diplomatic Notes in
2008. While Canada expressed its position before the final rule
published on January 7, upon review, we now have determined that the
concerns raised by the United States' treaty partner counsel in favor
of revocation of the rule.
In addition to the Canada Convention, the January 7 rule may also
be inconsistent with the migratory bird conventions with Mexico, Japan,
and Russia. The Japan and Russia Conventions both broadly call for the
parties to prevent damage to birds from pollution. See Convention
between the Government of the United States of America and the
Government of Japan for the Protection of Migratory Birds and Birds in
Danger of Extinction, and Their Environment, Mar. 4, 1972, 25 U.S.T.
3329 (Japan Convention); Convention between the United States of
America and the Union of Soviet Socialist Republics Concerning the
Conservation of Migratory Birds and Their Environment, Nov. 19, 1976,
29 U.S.T. 4647 (Russia Convention). The Protocols amending the Canada
and Mexico Conventions contain similar language calling for the parties
to seek means to prevent damage to birds and their environment from
pollution. See Protocol between the Government of the United States and
the Government of Canada Amending the 1916 Convention Between the
United Kingdom and the United States of America for the Protection of
Migratory Birds, Dec. 14, 1995, S. Treaty Doc. No. 104-28, T.I.A.S.
12721; Protocol Between the Government of the United States of America
and the Government of the United Mexican States Amending the Convention
for the Protection of Migratory Birds and Game Mammals, May 5, 1997, S.
Treaty Doc. No. 105-26.
Some of the relevant provisions include article IV of the Protocol
with Canada, which states that each party shall use its authority to
``take appropriate measures to preserve and enhance the environment of
migratory birds,'' and in particular shall ``seek means to prevent
damage to [migratory] birds and their environments, including damage
resulting from pollution''; article I of the Mexico Convention, which
discusses protecting migratory birds by ``means of adequate methods[. .
.]''; article VI(a) of the Japan Convention, which provides that
parties shall ``[s]eek means to prevent damage to such birds and their
environment, including, especially, damage resulting from pollution of
the seas''; and articles IV(1) and 2(c) of the Russia Convention, which
require parties to ``undertake measures necessary to protect and
enhance the environment of migratory birds and to prevent and abate the
pollution or detrimental alteration of that environment,'' and, in
certain special areas, undertake, to the maximum extent possible,
``measures necessary to protect the ecosystems in those special areas .
. . against pollution, detrimental
[[Page 54646]]
alteration and other environmental degradation.''
The January 7 rule eliminates a source of liability for pollution
that incidentally takes and kills migratory birds--a position that is
difficult to square with the mutually agreed upon treaty provisions
agreeing to prevent damage to birds from pollution. The January 7 rule
does not directly affect natural resource damage assessments conducted
under the Comprehensive Environmental Response Compensation and
Liability Act, the Oil Pollution Act, and the Clean Water Act to
determine compensation to the public for lost natural resources and
their services from accidents that have environmental impacts, such as
oil spills. However, for oil spills such as the BP Deepwater Horizon
Gulf oil spill and the Exxon Valdez oil spill in Alaska, significant
penalties were levied in addition to those calculated under natural
resource damage assessments based on incidental-take liability under
the MBTA. Those fines constituted a large proportion of the total
criminal fines and civil penalties associated with historical
enforcement of incidental take violations. As noted in the EIS, the
January 7 rule eliminates the Federal Government's ability to levy
similar fines in the future, thereby reducing the deterrent effect of
the MBTA and the Federal Government's ability to mitigate some of the
harm by directing these fines to the North American Wetlands
Conservation Act fund for the protection and restoration of wetland
habitat for migratory birds.
In sum, the issues raised by the Government of Canada raise
significant concerns regarding whether the January 7 rule is consistent
with the Canada Convention, and questions also remain regarding that
rule's consistency with the other migratory bird Conventions. We note
as well that the primary policy justifications for the January 7 rule
were resolving uncertainty and increasing transparency through
rulemaking. These concerns, however, do not outweigh the legal
infirmities of the January 7 rule or the conservation objectives
described above. In any case, the Service has issued a Director's Order
concurrently with this rule that explains in more detail our
enforcement priorities regarding incidental take of migratory birds and
published an advance notice of proposed rulemaking to seek public input
on an authorization framework. Both actions will provide the public
with more clarity and transparency regarding compliance with the MBTA.
On these bases, in addition to the legal concerns raised above, we
revoke the January 7 MBTA rule.
Public Comments
On May 7, 2021, the Service published in the Federal Register (86
FR 24573) a proposed rule seeking public comment on whether the Service
should revoke the final rule published on January 7, 2020, that defined
the scope of the MBTA as it applies to conduct resulting in the injury
or death of migratory birds protected by the Act. We solicited public
comments on the proposed rule for 30 days, ending on June 7, 2021. We
received 238 comments. Many comments included additional attachments
(e.g., scanned letters, photographs, and supporting documents). These
comments represented the views of multiple State and local government
agencies, private industries, nongovernmental organizations (NGOs), and
private citizens. In addition to the individual comments received, 3 of
those comments were petitions that contained a total of 42,610
individual signatures supporting the revocation of the January 7 rule.
We solicited public comments on the following topics:
1. Whether we should revoke the rule, as proposed, and why or why
not;
2. The costs or benefits of revoking the rule;
3. The costs or benefits of leaving the rule in place; and
4. Any reliance interests that might be affected by revoking the
rule, or not revoking the rule.
The following text presents the substantive comments we received
and the Service's response to them.
Comment: There are other statutes besides the MBTA that protect
birds, including NEPA, that industry would still have to comply with,
and birds would continue to benefit from those protections. State and
local laws also prevent the unnecessary killing of birds; therefore, it
is unnecessary for the Service to revoke the January 7 rule.
Service Response: The Service recognizes that there are numerous
reasons why an entity would continue to implement best practices,
including other Federal or State laws, industry standard practices,
public perception, etc. These mechanisms could reduce impacts to birds
in some circumstances, but do not provide the uniform conservation
protections that Federal regulation can provide. In any case, proper
interpretation of the MBTA does not change based on whether other
statutes or practices may be protective of migratory birds. Rather, the
interpretation must be guided by the MBTA itself. Here, the Service
believes the best path forward is to revoke the January 7 rule as it
presents an interpretation that is not the best interpretation of the
MBTA.
Comment: Several commenters stated that they were against
revocation of the rule because it would create uncertainty by returning
to inconsistent enforcement discretion when incidental take occurs
under the MBTA.
Service Response: The Service acknowledges that this final rule, by
its terms, simply revokes the January 7 rule by removing the regulatory
language at 50 CFR 10.14 and does not purport to replace that
regulation with new regulatory language at this time. However, upon
revocation of the rule, the Service expects to develop a comprehensive
regulatory framework governing MBTA compliance and enforcement to
reduce public uncertainty and provide consistent implementation of the
MBTA. To begin that process, we issued an advanced notice of proposed
rulemaking concurrently with publication of this final rule that
requests public input on a potential regulatory framework for
authorizing incidental take under the MBTA. In addition, while
certainty in application of the law is a significant consideration,
ultimately the Service must interpret and implement the MBTA in a
manner that best effectuates Congress' intent. For the reasons
explained herein, the Service believes that the January 7 rule does not
reflect the best reading of the MBTA's text, purpose, and history and
therefore should be revoked.
Comment: Several commenters stated they were against the revocation
of the final rule as it would create undue economic burden and expose
industry to prosecution.
Service Response: The Service acknowledges that implementing best
practices to reduce bird mortality from some industry sectors can
include increased costs. However, during the January 7 rulemaking
process, most industry sectors informed the Service that they would
continue to implement best practices regardless of our regulatory
position. Thus, we do not expect a significant increase in economic
burden on these industries. Moreover, while consideration of regulatory
burdens is undoubtedly important, ultimately the Service's
interpretation of the MBTA must be guided by the MBTA itself.
Comment: The proposed rule does not reconcile varying court
decisions or discuss how the Service would address MBTA enforcement.
Service Response: Upon revocation of the January 7 rule, the
Service will apply enforcement discretion and not prioritize
investigating projects that
[[Page 54647]]
implement best practices to avoid and minimize impacts to migratory
birds. Enforcement of the MBTA would be applied consistent with
applicable case law. As noted in the proposed rule preamble, reference
to case law can be used to bolster either interpretation as
demonstrated by the relevant analysis in the January 7 rule concluding
that case law bolsters the interpretation that the MBTA does not
prohibit incidental take versus the opposite conclusion in the initial
Solicitor's Opinion, M-37041. Thus, case law is of limited assistance
and cannot be reconciled in adopting either interpretation. On balance,
we conclude that case law generally favors an interpretation that the
MBTA prohibits incidental take as explained in M-37041, but we
acknowledge there are cases, such as the CITGO case in the Fifth
Circuit Court of Appeals, that adopt the opposite interpretation. In
the longer term, the Service expects to implement a comprehensive
regulatory framework governing MBTA compliance and enforcement to
reduce public uncertainty and provide consistent implementation of the
MBTA.
Comment: Some commenters stated that the rule should not be revoked
until an enforcement policy, general permit system, or de minimis
standard for incidental take is developed.
Service Response: Given the Service's conclusion that the January 7
rule does not reflect the best interpretation of the MBTA, the Service
decided that the appropriate initial step is to immediately revoke that
rule before the Service considers a replacement policy or regulation.
The Service issued a Director's Order concurrently with this final rule
that clarifies how the MBTA will be implemented and enforced after this
final rule becomes effective. The Service will consider developing an
appropriate regulatory framework to authorize incidental take
consistent with application of best management practices in the future.
Comment: Several commenters stated that they were neutral regarding
revocation of the rule, but that if the Service finalized revocation,
it should then promulgate a rule that creates a permitting program so
that industry would have a means of compliance and legal certainty.
Service Response: Upon revocation of the January 7 rule, the
Service will evaluate options to develop a formal approach to authorize
compliance with the MBTA in the context of incidental take of migratory
birds.
Comment: Some commenters stated they will continue to use best
practices to avoid and minimize bird mortality regardless of the
regulatory approach adopted by the Service.
Service Response: The Service acknowledges and appreciates industry
efforts to reduce impacts on migratory birds regardless of MBTA policy
positions. The Service envisions any future regulatory approach to
authorizing incidental take will be rooted in the implementation of
industry best practices. We will continue to work with industry to
provide guidance on the appropriateness and implementation of those
best practices.
Comment: Some commenters stated that, while reversing the rule was
a positive first step, it must be followed by rulemaking that
establishes an incidental take permitting system.
Service Response: Upon revocation of the January 7 rule, the
Service will evaluate options for developing a regulatory approach to
resolve any uncertainties pertaining to MBTA compliance. In the short
term, the Service issued a Director's Order clarifying our current
enforcement position and an advanced notice of proposed rulemaking to
inform development of a longer-term proposal to implement an incidental
take authorization framework.
Comment: The Service should revoke the January 7 rule and return to
the previous interpretation that incidental take is prohibited by the
MBTA because that interpretation is more aligned with judicial
precedent.
Service Response: We agree that the interpretation that incidental
take is prohibited under the MBTA is consistent with judicial precedent
in many jurisdictions and is the best interpretation of the law. Upon
revocation of the January 7 rule, we will return to our prior
interpretation that the MBTA prohibits incidental take. However, we
will also engage in rulemaking to codify the interpretation that the
MBTA prohibits incidental take to provide the public with greater
clarity regarding what violations of the MBTA we will prioritize for
enforcement.
Comment: One commenter argued that if the January 7 rule is
revoked, all contracts affected by reliance on the January 7 rule need
to be grandfathered to avoid impacting the terms under which those
contracts were negotiated.
Service Response: Any contracts entered into that may be affected
by reliance on the January 7 rule are not within the Service's
jurisdiction to address. The Service does not have the authority to
mandate any alteration of private contracts, nor does it believe it
necessary to create a regulatory carve-out for contracts negotiated in
good faith and placed into effect during the period between March 8
when the January 7 rule went into effect and the date this final rule
will become effective (see DATES). We will continue to work with
companies on a case-by-case basis and encourage implementation or
continued use of best management practices that avoid or minimize
incidental take of migratory birds. We will consider any potential
effect of reliance on the short-term applicability of the January 7
rule in working with those companies and in prioritizing our
enforcement resources.
As noted above, the Service requested comments on specific reliance
interests that might be affected by revocation of the rule. We received
several comments such as this one that generally stated how reliance
interests may be affected by revoking the rule but without providing
specific instances to corroborate those statements. No commenters
identified any specific circumstances or situations where entities had
relied on the January 7 rule and as a result their reliance interest
would be affected by the rule's revocation. Moreover, many commenters
noted that entities would continue to implement best management
practices and conservation measures for a variety of reasons despite
the January 7 rule, including compliance with federal and state
regulations other than the MBTA.
Comment: Revocation of the January 7 rule is appropriate because
birds provide substantial economic benefits via recreational bird
watching/hunting and fines for MBTA violations contribute to bird
conservation actions.
Service Response: The Service agrees that birds provide significant
economic benefits for bird watching, bird hunting, and general
enjoyment by the American public. Birds also provide critical
ecosystems services reducing the costs and need for pest control,
pollination, and other services beneficial to humans.
Comment: Many commenters supported revocation of the January 7 rule
and urged the Service to work with States and industries to find best
practices to balance industry needs and bird protections.
Service Response: The Service has and will continue to work with
Federal and State agencies, NGOs, and industry to identify, develop,
and evaluate actions that either avoid or minimize the impacts to
migratory birds. The Service will continue to develop policies and
regulations to further develop this cooperative approach. This approach
will provide a resilient, long-term framework for implementing the MBTA
that will provide long-term certainty to the regulated community
[[Page 54648]]
and improved conservation of migratory birds.
Comment: Revoking the January 7 rule is best for bird conservation
and reduces the chance that a species may eventually need to be listed
as threatened or endangered.
Service Response: The Service agrees that working with Federal and
State agencies, NGOs, and industry to avoid and minimize the incidental
take of migratory birds is critical to the conservation of migratory
birds and may reduce the number of bird species that require protection
under the Endangered Species Act in the long term.
Comment: Existing science supports leaving the January 7 rule in
place because predators are a significant source of threats to
migratory birds according to a Service website (https://www.fws.gov/birds/bird-enthusiasts/threats-to-birds.php). Thus, the Service should
focus its efforts and use scientifically sound conservation and
policies to address those impacts.
Service Response: The Service agrees that predators are a source of
mortality for birds. However, the rule the Service revokes applies to
the incidental take of birds caused directly by human activities, not
to predator impacts in general. Incidental take of birds is a leading
cause of avian mortality, and the Service's revocation of the January 7
rule will help reduce the effects of incidental take on migratory bird
populations. Moreover, proper interpretation of the MBTA does not
change based on whether non-human factors adversely impact migratory
birds. Rather, the interpretation must be guided by the MBTA itself.
Comment: The January 7 rule should be revoked because the MBTA has
proven to be a highly successful tool for co-management, regulation,
and mitigation of negative effects on migratory bird populations across
State and international borders, strengthening the collaborative
conservation efforts between State, Tribal, territorial, provincial,
and Federal agencies as well as the four regional Flyway Councils.
State agencies and their conservation partners have long expressed the
need for the protections this rule would provide.
Service Response: The Service agrees the MBTA is one of the best
tools for the conservation and management of migratory birds and looks
forward to working with all stakeholders in developing additional steps
to clarify its implementation of the MBTA in the context of incidental
take. The Service will provide the public with opportunities to comment
on reasonable implementation alternatives throughout that process.
Comment: Repeal of the January 7 rule would greatly expand the
Service's interpretation of the MBTA and expose incidental-take
violations to criminal prosecution.
Service Response: The commenter is correct that revoking the
January 7 rule will allow for prosecution of actions that incidentally
take migratory birds. The Service will rely on judicious use of
enforcement discretion to determine whether to enforce the statute in
these situations as it did for decades prior to the recent change in
interpretation codified by the January 7 rule.
Comment: The interpretation of the MBTA codified at 50 CFR 10.14 by
the January 7 rule better accords with the language and purpose of the
MBTA as passed by Congress. Focusing on the plain language of the MBTA
and appropriate canons of statutory construction results in an
interpretation consistent with that codified at 50 CFR 10.14, which
thus should not be revoked.
Service Response: We disagree with the commenter for the reasons
spelled out in the preamble to this final rule. Applying canons of
statutory construction to the relevant language in the MBTA has
resulted in courts reaching opposite conclusions regarding whether the
plain language of the MBTA prohibits or excludes incidental take of
migratory birds.
Comment: The Service should consult with other Federal agencies,
including the Department of Justice to ensure that this rulemaking is
constitutional.
Service Response: This rulemaking has undergone a rigorous
interagency review process, as required by Executive Order 12866.
Comment: The Service's interpretation of the MBTA is not entitled
to Chevron deference because Chevron deference is an unconstitutional
abdication of the judicial role of independent judgment, violates the
separation of powers, and contravenes due process.
Service Response: The Service is revoking the January 7 rule
because it does not represent the best interpretation of the MBTA,
whether the operative statutory language is plain or ambiguous. We do
not opine here on the constitutionality of Chevron deference. Any
concerns about whether the case giving rise to the concept of Chevron
deference was correctly decided are both outside the Service's
jurisdiction under the MBTA and, more to the point, not directly
relevant to our decision to revoke the January 7 rule.
Comment: The proposed rule incorrectly focuses on five of the acts
prohibited by the MBTA in section 703. But section 703 prohibits 22
acts, almost all of which involve deliberate acts. Thus, application of
the noscitur a sociis canon strongly favors interpreting the prohibited
acts to involve deliberate actions. Even if ``take,'' ``kill,'' and
even ``capture'' are ambiguous terms that could apply to both direct
and indirect actions, there are 19 other terms that apply to direct
actions; therefore, the most natural reading is that Congress intended
all 22 terms to apply to deliberate acts directed at migratory birds.
Service Response: As both the proposed rule, the January 7 rule,
and the Jorjani Opinion all conclude, the operative terms that are
relevant to determining whether the MBTA prohibits incidental take are
the five terms ``hunt, pursue, capture, kill, and take.'' The remaining
17 terms all relate to activities that comprise commercial use of
migratory birds, which necessarily entail an act directed at migratory
birds given they all require possession or attempted possession. The 17
actions related to commercial use are simply not relevant to whether
the MBTA prohibits incidental taking or killing of migratory birds.
Those actions are only relevant once a migratory bird has already been
taken, captured, or killed. Given that at least two, and likely three,
of the five operative terms are ambiguous and could apply to direct or
incidental actions, application of the noscitur a sociis canon to
bolster either interpretation is highly suspect.
Comment: The Service's reliance on the military-readiness
authorization mandated by the Stump Act to demonstrate that Congress
interpreted the MBTA at that time to prohibit incidental take is
misplaced. The Stump Act stated that the MBTA does not apply to
incidental take during military-readiness activities in the first place
and mandated that the Service issue a regulation acknowledging that
such activities are not subject to the MBTA. The Stump Act provides for
the continued exemption of any incidental take caused by military-
readiness activities rather than providing for an authorization of
incidental take by the Service.
Service Response: This argument relies on a selective reading of
the Stump Act. The Stump Act's statement that the MBTA does not apply
to military-readiness activities was not a general statement of the
MBTA's applicability at that time, but instead a specific and temporary
exemption for incidental take caused by military-
[[Page 54649]]
readiness activities until the Service developed and published a rule
specifically exempting those activities. Far from proving that the
Service never had authority to prohibit incidental take caused by
military-readiness activities in the first place, the explicit
temporary nature of the exemption strongly implies the exact opposite.
Moreover, the rule promulgated by the Service with the concurrence of
the Secretary of Defense as required by the Stump Act calls for
suspension or withdrawal of the authorization if certain conditions
occur. Thus, the permanence of the exemption is conditional. The Stump
Act describes the relevant regulations to be prescribed as both
``authorizing incidental take'' and ``to exempt the Armed Forces for
the incidental take of migratory birds.'' Thus, it is certainly
reasonable to infer that the Service may condition that take as it did
in the military-readiness rule whatever label is given to that
authority.
Comment: The proposed revocation rule suggests that the Stump Act's
explicit authorization of incidental take during military readiness
activities ``reflects a change in Congress' `governing understanding'
of the MBTA, and that henceforth incidental take from any activity
other than military readiness activities could be criminally
prosecuted.''
Service Response: This is a mischaracterization of the proposed
rule that echoes the Fifth Circuit's analysis of the Stump Act in
CITGO. The Service does not argue that the military-readiness
authorization represented a change in congressional interpretation of
the MBTA that suddenly applied incidental take prohibitions to all
activities not involving military readiness. In fact, the opposite is
true. The Stump Act makes clear that Congress already interpreted the
MBTA to prohibit incidental take and the military-readiness exception
would simply not have been necessary if Congress had instead considered
the MBTA to exclude incidental take at that time. If Congress had
considered the scope of the MBTA to exclude incidental take at the time
and simply wanted to shield the military from further litigation over
its military-readiness activities, it could easily have signaled that
intent and clarified that it did not consider the MBTA to prohibit
incidental take. The specific exceptions from the authorization in the
legislation for non-readiness activities such as the routine operation
of installation operating support functions are best understood not to
support a reading that the authorization was intended as a narrow
exemption to shield the military from further MBTA litigation even
though Congress considered the MBTA not to prohibit incidental take.
Comment: If the Service revokes the January 7 rule, it will be free
to use the responsible-corporate-officer doctrine to bring criminal
charges against corporate executives whose companies may cause
incidental harm to migratory birds.
Service Response: Decisions regarding whether to file criminal
charges are made by the Department of Justice, in accordance with
publicly available policies of that Department. In the decades prior to
the January 7 rule, the Service is not aware of charges having been
brought by the Department of Justice against corporate executives for
incidental take, under the MBTA, caused by their companies.
Comment: Application of the MBTA to incidental take is inconsistent
with the Service's general regulation defining ``take'' to mean ``to
pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt
[those acts].'' 50 CFR 10.12. Each of these words connotes an active
effort to harm a migratory bird and thus excludes actions that may
incidentally and indirectly lead to such harm.
Service Response: This argument is simply an extension of the
noscitur a sociis argument that relies on interpreting terms such as
``kill,'' ``wound,'' and ``capture'' as unambiguously referring to acts
directed at migratory birds because of their placement in a list of
other terms that can only be construed as directed at birds. However,
the fact that those terms could equally apply to incidental conduct
undermines that argument. Moreover, the Service clearly did not
interpret its own regulation in that manner when it enforced the MBTA
in the context of incidental take for over 40 years prior to
publication of the Jorjani Opinion. Moreover, Executive Order 13186,
which interprets the term ``take'' in 50 CFR 10.12 to apply to both
intentional and unintentional take, has not been amended or repealed
since its issuance in 2001 (66 FR 3853, January 17, 2001). The
Service's interpretation of 50 CFR 10.12 to apply to incidental taking
and killing in the context of the MBTA has been longstanding prior to
2017, and thus, the revocation rule is not breaking new ground and is
not inconsistent with that regulation.
Comment: The revocation of an existing rule requires an
environmental assessment under NEPA. Because the Service drafted an EIS
to accompany the original rule after determining it was a major Federal
action, revocation is also a major Federal action requiring further
NEPA review.
Service Response: Revocation of the existing rule and a return to
the Service's prior interpretation of the MBTA is addressed in the EIS
associated with the January 7 rule as Alternative B. We have issued a
new Record of Decision that reflects our selection of Alternative B and
describes how we will implement that alternative. Supplementation of
the prior EIS is not necessary as none of the criteria for
supplementation have been met. Our determination that supplementing the
prior EIS is not necessary is explained in more detail in the Record of
Decision (ROD) associated with this revocation rule, which is available
at https://www.fws.gov/regulations/mbta/resources.
Comment: It is improper to ignore three different circuit court
conclusions that conclude the MBTA does not prohibit incidental take
and instead rely on a district court decision.
Service Response: As explained in the preamble to this final rule,
we have not ignored the conclusions of any of the circuit courts that
have ruled on this issue. One circuit court has clearly held that the
MBTA does not prohibit incidental take, and two circuit courts have
held that it does. Other circuit courts have opined on the issue in
dicta. We have assessed all these court decisions in reaching our
decision to revoke the January 7 rule.
Comment: The Service should not write a regulation to declare the
scope and meaning of a statute over 100 years after its enactment. The
Service should revoke the January 7 rule but should not replace it with
a regulation codifying a different interpretation of the MBTA.
Service Response: While we agree with the commenter that the
January 7 rule should be revoked, we do not agree that the Service
lacks authority to interpret the MBTA. Congress specifically provided
the Secretary of the Interior with the authority to implement the MBTA.
The Secretary has delegated that authority to the Service.
Implementation of legislation often requires an agency to clarify
language in the statute that is ambiguous and impliedly left to the
agency's discretion to interpret and clarify. An agency may also
clarify the plain meaning of a statute if it determines there is no
ambiguity.
Comment: Revoking the January 7 rule would result in significant
uncertainty and potentially harsh and inequitable consequences for key
sectors of U.S. industry through a return to uneven enforcement
discretion.
Service Response: The Service agrees that splits of opinion in
circuit courts regarding the applicability of incidental
[[Page 54650]]
take requires clarification, which the Service has the authority to
address through enforcement discretion and policy. However, the Service
has a history of working with industry to employ best practices to
reduce incidental take under the MBTA and pursued only the most
egregious offenders. Thus, the Service disagrees that application of
enforcement discretion will result in ``harsh and inequitable
consequences.'' Further, the Service will continue to develop clearer
standards for regulation of incidental take to reduce uncertainty and
to ensure enforcement is not uneven. We have also issued a Director's
Order concurrently with this final rule that clarifies our current
enforcement position and how the Service will prioritize enforcement
actions when this rule becomes effective.
Comment: The Service should retain a bright-line standard that the
MBTA does not prohibit incidental take. A bright-line rule provides
important certainty to a wide range of entities.
Service Response: While we disagree that the MBTA does not prohibit
incidental take, we agree that a bright-line standard is a preferable
long-term solution to address actions that incidentally take migratory
birds. We will continue to work, after publication of this revocation
rule, to develop a bright-line standard governing regulation of
incidental take under the MBTA that provides certainty to regulated
entities.
Comment: Retaining the January 7 rule will not result in
significant negative impacts to avian species because companies are
already motivated to conserve those species through implementation of
best management practices and are already subject to a wide range of
other Federal, State, and local avian protection laws.
Service Response: The Service understands that a number of other
Federal, State, and local laws and regulations provide some protection
to birds. However, these laws and regulations vary by State, and
companies are currently free to cease best practices that were
undertaken based on compliance with the MBTA. This situation has
significant potential for negative impacts to migratory birds from
current and future industry projects.
Comment: Retaining the January 7 rule will promote better dialogue
and more cooperation by removing the potential for negative
repercussions resulting from candid communications with the Service.
Companies will work more collaboratively with the Service in an
environment of certainty and mutual understanding. Current efforts are
supporting migratory birds and reducing impacts, including voluntary
efforts like the Land-based Wind Energy Guidelines and Avian Protection
Plan Guidelines for power lines, as well as grant programs like
America's Conservation Enhancement Act of 2020, Neotropical Migratory
Bird Conservation Act, Great American Outdoors Act, Farm Bills, and the
North American Waterfowl Management Plan.
Service Response: The Service agrees that industries attempting to
employ best practices deserve encouragement and support from the
Service, including candid communications. The Service will continue to
work collaboratively after revocation of this rule to create clear and
achievable standards for regulated entities. The Service agrees that
the grant programs mentioned help to conserve and restore habitat for
migratory birds and that the guidelines provide useful suggestions that
some industries may follow to help avoid or reduce incidental take of
migratory birds. The Service concludes, however, that prohibition of
incidental take is consistent with the best interpretation of the MBTA
and that this tool is necessary to help slow the decline of many
species of migratory birds.
Comment: One commenter stated that the January 7 rule should not be
revoked because it provides regulatory certainty and supports current
efforts to improve U.S. infrastructure.
Service Response: While the Service agrees that the January 7 rule
provides regulatory certainty, we also believe that prohibition of
incidental take is consistent with the best legal interpretation under
the MBTA. Further, the Service has a long track record of working with
industry to avoid and minimize incidental take while also allowing
infrastructure plans to proceed. The Service disagrees with the
assertion that revoking the January 7 rule will inevitably add
significant cost and delays to the implementation of infrastructure
programs, nor does it agree with the assertion that protecting
migratory birds from incidental take will delay climate benefits
provided by new, resilient infrastructure.
Comment: The Service has failed to provide an adequate rationale
for its change in policy and position on whether the MBTA prohibits
incidental take, and thus violates the Administrative Procedure Act.
Service Response: We respectfully disagree and refer the commenter
to the detailed explanation and rationale provided in the preamble to
this rule. It is important to note that this rule, by its terms, does
nothing more than revoke the language at 50 CFR 10.14 that codifies an
interpretation that the MBTA does not prohibit incidental take. We are
not proposing replacement language at this time. However, we will
propose to do so in the near future and continue to develop and publish
policies and regulations that provide the public with greater certainty
regarding compliance with the MBTA.
Comment: In the January 7 rule, the Service stated it had grave
constitutional due process concerns with the prior agency practice of
using enforcement discretion to implement the Service's prior
interpretation that the MBTA prohibits incidental take. The Service has
not explained why those due process concerns have disappeared in
considering revocation of the January 7 rule.
Service Response: In promulgating this revocation rule, we
reevaluated the constitutional concerns we previously categorized as
grave. Our previous enforcement policy implemented prior to the Jorjani
Opinion was exercised judiciously, focusing on implementation of best
practices by various industries to mitigate incidental take of
migratory birds. The Service's practice was to notify industries that
their actions caused incidental take and give them an opportunity to
implement best practices to avoid or mitigate that take prior to
bringing any enforcement action. This approach is entirely consistent
with that set forth by the Tenth Circuit Court of Appeals in United
States v. Apollo Energies, an approach the court considered would
alleviate any due process concerns associated with using enforcement
discretion to implement the statute in the context of incidental take.
A close examination of the past history of the Service's exercise of
enforcement discretion simply does not invoke significant
constitutional due process concerns. Moreover, after revocation of the
January 7 rule, we will develop further policy to implement our
interpretation that the MBTA prohibits incidental take to provide the
public with greater certainty regarding enforcement, including
promulgating a regulation that codifies our current interpretation of
the MBTA. We have also issued a Director's Order concurrently with the
publication of this rule that explains in more detail our enforcement
priorities regarding incidental take of migratory birds and published
an advance notice of proposed rulemaking to seek public input on an
authorization framework. Both actions will provide the public with more
clarity regarding compliance with the MBTA and alleviate any
[[Page 54651]]
potential remaining constitutional due process concerns.
Comment: The Service should take public comment on alternatives to
the proposed revocation rather than framing the proposed rule as a
take-it-or-leave-it offer.
Service Response: At this stage, the Service simply proposed to
revoke the January 7 rule and return to the longstanding prior agency
practice of interpreting the MBTA to prohibit incidental take. The
alternatives of keeping the rule in place or revoking it are entirely
consistent with the alternatives proposed during development of the
January 7 rule and analyzed in the accompanying EIS. Thus, the proposal
to revoke that rule was entirely in keeping with the approach taken in
the January 7 rule itself. As explained in the Record of Decision for
this rulemaking, the Service will develop additional steps to clarify
its implementation of Alternative B of the EIS developed in association
with the January 7 rule. The Service will provide the public with
opportunities to comment on reasonable implementation alternatives
throughout that process.
Comment: Interpreting the MBTA to prohibit incidental take produces
absurd results, such as prosecution of bird deaths caused by
automobiles, airplanes, plate-glass modern office buildings, or picture
windows in residential buildings.
Service Response: This concern is simply not borne out by the
Service's past practice. The Service has not brought an enforcement
action for any of the actions presented by the commenter as absurd
targets of enforcement. Interpreting the MBTA to prohibit incidental
take has not led to absurd results in the past, and this past practice
demonstrates there is no reason to believe it will lead to absurd
results in the future. The Service also notes, as reflected in the
associated Record of Decision, that this revocation rule is simply the
first step in a process to implement a fair and public process to
clarify the scope of the MBTA as it relates to incidental take and
explain how regulated entities may comply with the MBTA in that
context.
Comment: Revoking the January 7 rule could potentially subject to
criminal liability an effectively limitless number of lawful everyday
activities. No one would have fair notice of which of their daily
activities could cause them to commit a Federal crime, and no one can
sufficiently conform their behavior to fully avoid that liability.
Service Response: We do not agree that simply revoking the January
7 rule will automatically subject a limitless number of everyday
activities to potential criminal liability. That scenario has never
been the case under the Service's past enforcement of the MBTA and will
not be the case after revocation of the January 7 rule. Prior to
issuance of the Jorjani Opinion, the Service followed the direction of
the 10th Circuit Court of Appeals in the United States v. Apollo
Energies case by providing potential violators with notice of any
activities that are causing incidental take and an opportunity to
correct or mitigate that take before considering moving forward with an
enforcement action. The Service has published an enforcement policy in
the form of a Director's Order concurrently with this rule and will
provide further clarification regarding its approach to enforcing the
MBTA after revocation of the January 7 rule. This approach will give
the regulated community fair notice of what actions the Service will
consider to be violations of the statute.
Comment: The Service should not use potential funding that could be
generated by criminalizing incidental take as a basis for revoking the
January 7 rule.
Service Response: The Service did not intend to suggest that
funding of the North American Wetlands Conservation Act fund through
criminal fines resulting from enforcement of incidental take provides a
basis for revoking the January 7 rule. Our intent in including this
information is to provide a complete accounting to the public on the
effect of the January 7 rule's codification of an interpretation that
the MBTA does not prohibit incidental take.
Comment: The Service should retain the January 7 rule and review
all MOUs (memorandums of understanding) drafted pursuant to Executive
Order 13186 to ensure they conform to the January 7 rule.
Service Response: Executive Order 13186 and any MOUs entered into
to comply with the Executive order have remained in effect through both
the January 7 rulemaking and this rulemaking to revoke the January 7
rule. The various interagency MOUs conform to the Executive Order and
are not contingent on any rulemaking interpreting whether the MBTA
prohibits or excludes incidental take.
Comment: The MBTA's reliance on criminal penalties may be an
appropriate deterrence for illegal hunting or trade, but not for
unintentional take. If the MBTA is read to apply to any and all take of
migratory birds, the agency is left to decide, with minimal direction,
what causes of bird mortality to pursue, and among those, what conduct
warrants sanctions. However, the Service can easily provide greater
certainty, and make better use of its own resources, through the
issuance of a formal MBTA enforcement policy issued contemporaneously
with adoption of the proposed revocation rule.
Service Response: The Service agrees that applying the MBTA to each
and every case of incidental take of a migratory bird is not feasible
or desirable and would not be an efficient use of agency resources. The
Service also agrees that issuing a formal enforcement policy upon
revocation of the January 7 rule would be beneficial and provide the
public with greater certainty regarding what activities may be subject
to enforcement. Therefore, the Service has issued an enforcement policy
in the form of a Director's Order upon publication of this rule to
revoke the January 7 rule as part of a broader strategy to provide the
public with greater certainty regarding what the MBTA prohibits along
with guidance to achieve compliance.
Comment: If the Service determines that revocation of the 2021 rule
is necessary, the Service must take the appropriate steps to resolve
the regulatory uncertainty and enforcement concerns that stem from that
approach. In promulgating regulations and establishing a program to
address incidental take, the Service must use the authority provided by
section 2 of the MBTA to craft exceptions to the conduct prohibited
under the MBTA.
Service Response: The Service will take this comment into account
in considering whether to develop an authorization framework for
incidental take after finalizing this revocation rule. The Service is
considering various methods to standardize enforcement, provide public
certainty, and authorize incidental take, but those issues are beyond
the scope of this rulemaking. Developing regulations that authorize
incidental take and provide specific exceptions are among the options
the Service is considering.
Comment: If the January 7 rule is revoked, one State agency stated
it will lose the benefit of being shielded from incidental take
liability when conducting habitat-enhancement activities, such as
prescribed burns. That State requested that the Service create an
exemption for such activities and proposed specific language for the
exemption.
Service Response: The Service will take this comment into account
in considering whether to develop an authorization framework for
incidental take after finalizing this revocation rule. We will also
consider the request for
[[Page 54652]]
exceptions or exemptions, as well as the specific language provided by
the commenter, in such a framework. We recognize that habitat-
enhancement activities, including prescribed burns, can result in
incidental take in the short term but can also provide positive
benefits to migratory birds in the medium-to-long term that may
outweigh any short-term incidental take. For these reasons, prescribed
burns following best management practices to enhance wildlife habitat
were not a priority for enforcement during the several decades the
Service interpreted the MBTA to prohibit incidental take prior to the
change in interpretation precipitated by the Solicitor's Opinion, M-
37050.
Comment: Given that the Trump administration's interpretation of
the MBTA was found invalid by a Federal court, the commenter was
concerned the Service's slow approach to revoking the rule and enacting
new rules to protect migratory birds will leave vulnerable bird
populations unprotected for an unnecessarily long period of time. We
encourage the Service to move quickly to restart enforcement of the
MBTA against industrial actions that lead to harm or death of birds.
Service Response: With this rule, the Service has revoked the
January 7 rule. We have issued a Director's Order concurrently with
this rule that explains our enforcement policy when the revocation rule
becomes effective.
Comment: Revoking the January 7 rule is a necessary first step to
comply with congressional language and intent and protect migratory
birds from additional population declines. But the Service must not
stop there. A robust regulatory system is necessary to reduce the rate
of incidental take associated with many types of commercial,
agricultural, and industrial activities. The energy and
telecommunications sectors in particular must be better regulated to
reduce incidental take.
Service Response: The Service does not intend revocation of the
January 7 rule to be the last step in implementing the MBTA. The
Service is considering various methods to standardize enforcement,
provide public certainty, and authorize incidental take. Developing
regulations that authorize incidental take by providing a permit
system, regulatory authorizations, or specific exceptions are among the
options the Service is considering.
Comment: The bycatch of seabirds in fisheries is a conservation
concern that the Service can effectively mitigate through the
establishment of a regulatory process that incorporates conservation
measures into incidental take permits.
Service Response: The Service agrees that incidental bycatch of
seabirds is a serious conservation concern. We will evaluate this
proposal as we consider and develop methods that include
standardization of enforcement, providing greater public certainty, and
potential authorization of incidental take.
Comment: The SBREFA (Small Business Regulatory Enforcement Fairness
Act) analysis and other potentially important analyses of the impacts
of the proposed revocation were missing from the rulemaking docket.
Service Response: The Service completed the SBREFA analysis and all
other required analyses and included the summary in the proposed rule
preamble. Unfortunately, the documents themselves were not included in
the rulemaking docket at www.regulations.gov with the proposed rule. To
resolve this issue, the Service made the initial regulatory flexibility
analysis and the revised regulatory impact analysis available for
public review and comment prior to finalizing this rule and the Record
of Decision (86 FR 38354, July 20, 2021).
Comment: One commenter recommended reopening public comment for 60
days with separate comment periods for the Regulatory Flexibility Act
analysis.
Service Response: The Service concluded that a 30-day comment
period was sufficient for this rulemaking. The Service also provided an
additional 30-day comment period for public review of the Regulatory
Flexibility Act analysis and regulatory impact analysis. The issues
central to this rulemaking have already been vetted through multiple
public comment periods for the January 7 rule and associated NEPA
analysis and the rule extending the effective date of the January 7
rule. Therefore, the Service concluded a 30-day comment period is
sufficient for this rulemaking.
Comment: The Service should allow Federal courts to determine the
scope of what the MBTA proscribes and adopt prosecutorial guidelines
that outline the circumstances in which the Federal Government will
file criminal prosecutions under the MBTA. The executive branch has
relied on the prosecutorial discretion approach to refrain from
prosecuting MBTA cases where there was no element of intentional
misconduct or grossly culpable negligence for decades. However, some
unwarranted prosecutions have occurred. The executive branch should
write fresh guidelines based on a standard of due care, rather than
strict liability, with the benefit of stakeholder input rather than the
Service codify its interpretation of the statute.
Service Response: The Service does not agree that waiting for
Federal courts to coalesce around a specific interpretation of the MBTA
is the correct path forward. Instead, the Service is developing
regulations and policy to provide the public and the regulated
community with a degree of certainty regarding what constitutes a
violation of the MBTA. We agree that an enforcement policy may be a
productive way to police incidental take under the MBTA, particularly
in the near term; accordingly, we have issued a Director's Order
concurrently with this final rule that explains how we will prioritize
our enforcement resources in the context of incidental take.
Comment: Malicious intent must be present in order to warrant
criminal proceedings for the take of migratory birds.
Service Response: The misdemeanor provision of the MBTA has long
been interpreted by Federal courts as a strict liability crime.
Requiring malicious intent before the Service initiates an enforcement
action would not be consistent with the statutory language or the
relevant court cases. However, as mentioned previously, the Service
issued a Director's Order concurrently with this final rule that
explains how we will prioritize our enforcement resources in the
context of incidental take.
Required Determinations
National Environmental Policy Act
Because we are revoking the January 7 MBTA rule, we rely on the
final EIS developed to analyze that rule in determining the
environmental impacts of revoking it: ``Final Environmental Impact
Statement; Regulations Governing Take of Migratory Birds,'' available
on http://www.regulations.gov in Docket No. FWS-HQ-MB-2018-0090. The
alternatives analyzed in that EIS cover the effects of interpreting the
MBTA to both include and exclude incidental take. In finalizing this
rule, we have published an amended Record of Decision that explains our
decision to instead select the environmentally preferable alternative,
or Alternative B, in the final EIS. Any additional, relevant impacts on
the human environment that have occurred subsequent to our initial
Record of Decision are described in the amended Record of Decision.
[[Page 54653]]
Government-to-Government Relationship With Tribes
In accordance with Executive Order 13175, ``Consultation and
Coordination with Indian Tribal Governments,'' and the Department of
the Interior's manual at 512 DM 2, we considered the possible effects
of this rule on federally recognized Indian Tribes. The Department of
the Interior strives to strengthen its government-to-government
relationship with Indian Tribes through a commitment to consultation
with Indian Tribes and recognition of their right to self-governance
and Tribal sovereignty.
We evaluated the January 7 rule that this rule would revoke under
the criteria in Executive Order 13175 and under the Department's Tribal
consultation policy and determined that the January 7 rule may have a
substantial direct effect on federally recognized Indian Tribes. We
received requests from nine federally recognized Tribes and two Tribal
councils for government-to-government consultation on that rule.
Accordingly, the Service initiated government-to-government
consultation via letters signed by Regional Directors and completed the
consultations before issuing the January 7 final rule. During these
consultations, there was unanimous opposition from Tribes to the
reinterpretation of the MBTA to exclude coverage of incidental take
under the January 7 rule. Thus, revoking the January 7 rule is
consistent with the requests of federally recognized Tribes during
those consultations.
Energy Supply Distribution
E.O. 13211 requires agencies to prepare statements of energy
effects when undertaking certain actions. As noted above, this rule is
a significant regulatory action under E.O. 12866, but the rule is not
likely to have a significant adverse effect on the supply,
distribution, or use of energy. The action has not been otherwise
designated by the Administrator of the Office of Information and
Regulatory Affairs (OIRA) in the Office of Management and Budget (OMB)
as a significant energy action. Therefore, no Statement of Energy
Effects is required.
Endangered Species Act
Section 7 of the Endangered Species Act of 1973, as amended (ESA;
16 U.S.C. 1531-44), requires that the Secretary of the Interior shall
review other programs administered by her and utilize such programs in
furtherance of the purposes of the Act (16 U.S.C. 1536(a)(1)). It
further states that each Federal agency shall, in consultation with and
with the assistance of the Secretary, insure that any action
authorized, funded, or carried out by such agency is not likely to
jeopardize the continued existence of any endangered species or
threatened species or result in the destruction or adverse modification
of critical habitat (16 U.S.C. 1536(a)(2)). We have determined that
this rule revoking the January 7 rule regarding the take of migratory
birds will have no effect on ESA-listed species within the meaning of
ESA section 7(a)(2).
Regulatory Planning and Review (Executive Orders 12866 and 13563)
Executive Order (E.O.) 12866 provides that OMB-OIRA will review all
significant rules. OMB-OIRA has determined that this rule is
economically significant. OIRA has also determined that this is a major
rule under Subtitle E of the Small Business Regulatory Enforcement
Fairness Act of 1996 (also known as the Congressional Review Act or
CRA). 5 U.S.C. 804(2). See OIRA Conclusion of E.O. 12866 Regulatory
Review of the MBTA, available at https://www.reginfo.gov/public/do/eoDetails?rrid=131383 (designating the MBTA rule as a major rule under
the CRA). The CRA provides that major rules shall not take effect for
at least 60 days after publication in the Federal Register (5 U.S.C.
801(a)(3)). This rule will therefore be submitted to each House of
Congress and the Comptroller General in compliance with the CRA. 5
U.S.C. 801(a).
Executive Order 13563 reaffirms the principles of E.O. 12866 while
calling for improvements in the nation's regulatory system to promote
predictability, to reduce uncertainty, and to use the best, most
innovative, and least burdensome tools for achieving regulatory ends.
The Executive order directs agencies to consider regulatory approaches
that reduce burdens and maintain flexibility and freedom of choice for
the public where these approaches are relevant, feasible, and
consistent with regulatory objectives. E.O. 13563 emphasizes further
that regulations must be based on the best available science and that
the rulemaking process must allow for public participation and an open
exchange of ideas. We have developed this final rule in a manner
consistent with these requirements.
This final regulation revokes the January 7 MBTA rule. The legal
effect of this rule removes from the Code of Federal Regulations (CFR)
the interpretation that incidental take of migratory birds is not
prohibited under the MBTA, based on the rationale explained in the
preamble. As explained in the preamble, the Solicitor's Opinion (M-
37050) that formed the basis for the January 7 rule was overturned in
court and has since been withdrawn by the Solicitor's Office. By
removing Sec. 10.14 from subpart B of title 50 CFR, USFWS would revert
to implementing the statute without an interpretative regulation
governing incidental take, consistent with judicial precedent. This
would mean that incidental take can violate the MBTA to the extent
consistent with the statute and judicial precedent. Enforcement
discretion will be applied, subject to certain legal constraints.
The Service conducted a regulatory impact analysis of the January 7
rule, which can be viewed online at http://www.regulations.gov in
Docket No. FWS-HQ-MB-2018-0090. In that analysis, we analyzed the
effects of an alternative (Alternative B) where the Service would
promulgate a regulation that interprets the MBTA to prohibit incidental
take consistent with the Department's longstanding prior
interpretation. By reverting to this interpretation, the Service views
the incidental take of migratory birds as a potential violation of the
MBTA, consistent with judicial precedent.
The primary benefit of this rule results from decreased incidental
take. While we are unable to quantify the benefits, we expect this rule
to result in increased ecosystem services and benefits to businesses
that rely on these services. Further, benefits will accrue from
increased birdwatching opportunities. The primary cost of this rule is
the compliance cost incurred by industry, which is also not
quantifiable based on current available data. Firms are more likely to
implement best practice measures to avoid potential fines.
Additionally, potential fines generate transfers from industry to the
government. Using a 10-year time horizon (2022-2031), the present value
of these transfers is estimated to be $149.3 million at a 7-percent
discount rate and $174.6 million at a 3-percent discount rate. This
would equate to an annualized value of $14.9 million at a 7-percent
discount rate and $17.5 million at a 3-percent discount rate.
Regulatory Flexibility Act and Small Business Regulatory Enforcement
Fairness Act
Under the Regulatory Flexibility Act (5 U.S.C. 601 et seq., as
amended by the Small Business Regulatory Enforcement Fairness Act
(SBREFA) of 1996 (Pub. L. 104-121)), whenever an agency is required to
publish a notice of rulemaking for any proposed or final
[[Page 54654]]
rule, it must prepare and make available for public comment a
regulatory flexibility analysis that describes the effects of the rule
on small businesses, small organizations, and small government
jurisdictions. However, in lieu of an initial or final regulatory
flexibility analysis (IRFA or FRFA), the head of an agency may certify
on a factual basis that the rule would not have a significant economic
impact on a substantial number of small entities.
SBREFA amended the Regulatory Flexibility Act to require Federal
agencies to provide a statement of the factual basis for certifying
that a rule would not have a significant economic impact on a
substantial number of small entities. Thus, for an IRFA/FRFA to be
required, impacts must exceed a threshold for ``significant impact''
and a threshold for a ``substantial number of small entities.'' See 5
U.S.C. 605(b). We prepared a FRFA, briefly summarized below, to
accompany this rule that can be viewed online at http://www.regulations.gov in Docket No. FWS-HQ-MB-2018-0090.
This final rule may affect industries that typically incidentally
take substantial numbers of birds and with which the Service has worked
to reduce those effects (table 1). In some cases, these industries have
been subject to enforcement actions and prosecutions under the MBTA
prior to the issuance of M-37050. The vast majority of entities in
these sectors are small entities, based on the U.S. Small Business
Administration (SBA) small business size standards. It is important to
note that many small businesses will not be affected under this rule.
Only those businesses that reduced best management practices that avoid
or minimize incidental take of migratory birds as a result of the
issuance of M-37050 in January 2017 and the January 7, 2021, rule will
incur costs. The following analysis determines whether a significant
number of small businesses reduced best management practices and will
be impacted by this rule.
Table 1--Distribution of Businesses Within Affected Industries
----------------------------------------------------------------------------------------------------------------
Small business
Number of size standard Number of
NAICS industry description NAICS code businesses (number of small
employees) businesses
----------------------------------------------------------------------------------------------------------------
Finfish Fishing................................ 114,111 1,210 \a\ 20 1,185
Crude Petroleum and Natural Gas Extraction..... 211,111 6,878 1,250 6,868
Drilling Oil and Gas Wells..................... 213,111 2,097 1,000 2,092
Solar Electric Power Generation................ 221,114 153 250 153
Wind Electric Power Generation................. 221,115 264 250 263
Electric Bulk Power Transmission............... 221,121 261 500 214
Electric Power Distribution.................... 221,122 7,557 1,000 7,520
Wireless Telecommunications Carriers (except 517,312 15,845 1,500 15,831
Satellite)....................................
----------------------------------------------------------------------------------------------------------------
Source: U.S. Census Bureau, 2012 County Business Patterns.
\a\ Note: The SBA size standard for finfish fishing is $22 million. Neither Economic Census, Agriculture Census,
nor the National Marine Fisheries Service collect business data by revenue size for the finfish industry.
Therefore, we employ other data to approximate the number of small businesses. Source: U.S. Census Bureau,
2017 Economic Annual Survey.
Since the Service does not currently have a permitting system
dedicated to authorizing incidental take of migratory birds, the
Service does not have specific information regarding how many
businesses in each sector implement measures to reduce incidental take
of birds. Not all businesses in each sector incidentally take birds. In
addition, a variety of factors would influence whether, under the
previous interpretation of the MBTA, businesses would implement such
measures. It is also unknown how many businesses continued or reduced
practices to reduce the incidental take of birds since publication of
the Solicitor's Opinion M-37050 or issuance of the January 7 rule. The
Service specifically requested public comment on any reliance interests
on the January 7 rule. We did not receive sufficient information on
that issue during the public comment periods associated with the
January 7 rule and associated NEPA analysis, the February 9 rule
extending the effective date of the January 7 rule, or the proposed
rule and no comments were submitted by any entities identifying reduced
implementation of measures that would have to be reinstated when this
rule becomes effective. We did receive comments that stated that they
did not reduce best management practices after the January 7 rule.
These comments support our estimate that most entities did not reduce
best management practices as a result of the January 7 rule excluding
incidental take from the scope of the MBTA. In revoking the January 7
rule, any subsequent incidental take of migratory birds could violate
the MBTA, consistent with the statute and judicial precedent. Some
small entities will incur costs if they reduced best management
practices after M-Opinion 37050 was issued in January 2017 or after
promulgation of the January 7, 2021, rule and will need to subsequently
reinstate those practices if the January 7 rule is revoked, assuming
they did not already reinstate such practices after vacatur of M-
Opinion 37050.
Summary
Table 2 identifies examples of bird mitigation measures, their
associated costs, and why available data are not extrapolated to the
entire industry sector or small businesses. We requested public comment
so we can extrapolate data, if appropriate, to each industry sector and
any affected small businesses. In response, we received information
from the solar industry, which we utilized in this analysis where
applicable. Table 3 summarizes likely economic effects of the rule on
the business sectors identified in table 1. In many cases, the costs of
actions businesses typically implement to reduce effects on birds are
small compared to the economic output of business, including small
businesses, in these sectors. The likely economic effects summarized in
table 3 were collected during the public comment periods associated
with the January 7 rule and associated NEPA analysis, the February 9
rule extending the effective date of the January 7 rule, and the
proposed rule.
[[Page 54655]]
Table 2--Best Management Practices Costs by Industry \1\
----------------------------------------------------------------------------------------------------------------
Why data are not
Example of bird extrapolated to entire
NAICS industry mitigation measure Estimated cost industry or small
businesses
----------------------------------------------------------------------------------------------------------------
Finfish Fishing (NAICS 11411)........ Changes in design of Costs are per No data
longline fishing vessel per year. available on fleet
hooks, changes in $1,400 for size.
offal management thawed blue-dyed bait.. No data
practices, use of $150 for available on how many
flagging or streamers strategic offal measures are employed
on fishing lines. discards.. on each vessel.
$4,600 for
Tori line..
$4,000 one-
time cost for
underwater setting
chute..
$4,000 initial
and $50 annual for
side setting..
Crude Petroleum and Natural Gas Netting of oil $130,680 to Infeasible to
Extraction NAICS (211111). pits and ponds. $174,240 per acre to net pits larger than 1
Closed net ponds. acre due to sagging.
wastewater systems.. Most netted Size
pits are \1/4\ to \1/ distribution of oil
2\ acre.. pits is unknown.
Cost not Average number
available for of pits per business
wastewater systems.. is unknown.
Closed
wastewater systems
typically used for
reasons other than
bird mitigation.
Drilling Oil and Gas Wells (NAICS Netting of oil $130,680 to Infeasible to
213111). pits and ponds. $174,240 per acre to net pits larger than 1
Closed loop net ponds. acre due to sagging.
drilling fluid Cost not Size
systems.. available for closed distribution of oil
loop drilling fluid pits is unknown.
systems, but may be a Average number
net cost savings in of pits per business
arid areas with water is unknown.
conservation Closed loop
requirements. drilling fluid systems
typically used for
reasons other than
bird mitigation.
High
variability in number
of wells drilled per
year (21,200 in 2019).
Solar Electric Power Generation Pre- and post- $3,000 for two rounds New projects can vary
(NAICS 221114). construction bird of bird surveys on 200- from 100 to 5,000
surveys. acre site for pre-and acres in size, and
Compliance post-construction, and mortality surveys may
with Avian Power Line up to $10,000 if not scale linearly.
Interaction Committee travel and site
standards. preparation included.
Installation
of anti-perch devices..
Light
management measures..
Storage of
water in covered
tanks..
Wind Electric Power Generation (NAICS Pre- Cost not Data not
221115). construction available for available for
adjustment of turbine adjustment of turbine adjustment of turbine
locations to minimize construction locations. construction
bird mortality during $100,000 to locations.
operations. $500,000 per facility High
Pre- and post- per year for pre- variability in survey
construction bird construction site use costs and high
surveys. and post-construction variability in need to
Retrofit power bird mortality surveys. conduct surveys.
poles to minimize $7,500 per High
eagle mortality. power pole with high variability in cost
variability of cost. and need to retrofit
Annual power poles.
nationwide labor cost
to implement wind
energy guidelines:
$17.6M.
Annual
nationwide non-labor
cost to implement wind
energy guidelines:
$36.9M.
Electric Bulk Power Transmission Retrofit power poles to $7,500 per power pole High variability in
(NAICS 221121). minimize eagle with high variability cost and need to
mortality. of cost. retrofit power poles.
Electric Power Distribution (NAICS Retrofit power poles to $7,500 per power pole High variability in
221122). minimize eagle with high variability cost and need to
mortality. of cost. retrofit power poles.
Wireless Tele-communications Carriers Extinguish non- Industry saves Data not available for
(except Satellite) (NAICS 517312). flashing lights on hundreds of dollars number of operators
towers taller than per year in who have implemented
350'. electricity costs by these practices.
Retrofit extinguishing lights.
towers shorter than Retrofitting
350' with LED flashing with LED lights
lights. requires initial cost
outlay, which is
recouped over time due
to lower energy costs
and reduced
maintenance.
----------------------------------------------------------------------------------------------------------------
\1\ Sources: FWS personnel, National Oceanic and Atmospheric Administration Revised Seabird Regulations
Amendment, eccnetting.com, statista.com, aerion.com, FWS Wind Energy Guidelines, FWS Public Records Act data,
FWS Eagle Conservation Plan Guidance.
Table 3--Summary of Economic Effects on Small Businesses
----------------------------------------------------------------------------------------------------------------
Potential bird
NAICS industry description mitigation measures Economic effects on small Rationale
(NAICS Code) under this rule businesses
----------------------------------------------------------------------------------------------------------------
Finfish Fishing (11411)......... Changes in design Likely minimal effects.......... Seabirds are
of longline specifically excluded
fishing hooks, from the definition of
changes in offal bycatch under the
management Magnuson-Stevens
practices, and Fishery Conservation
flagging/streamers and Management Act
on fishing lines. and, therefore,
seabirds not listed
under the ESA may not
be covered by any
mitigation measures.
The impact of this on
small entities is
unknown.
Crude Petroleum and Natural Gas Using closed waste- Likely minimal effects.......... Thirteen States have
Extraction (211111). water systems or regulations governing
netting of oil the treatment of oil
pits and ponds. pits such as netting
or screening of
reserve pits,
including measures
beneficial to birds.
In addition, much of
the industry is
increasingly using
closed systems, which
do not pose a risk to
birds. For these
reasons, this rule is
unlikely to affect a
significant number of
small entities.
[[Page 54656]]
Drilling Oil and Gas Wells Using closed waste- Likely minimal effects.......... Thirteen States have
(213111). water systems or regulations governing
netting of oil the treatment of oil
pits and ponds. pits, such as netting
or screening of
reserve pits,
including measures
beneficial to birds.
In addition, much of
the industry is
increasingly using
closed systems, which
do not pose a risk to
birds. For these
reasons, this rule is
unlikely to affect a
significant number of
small entities.
Solar Electric Power Generation Monitoring bird use Likely minimal effects.......... Bird monitoring in some
(221114). and mortality at States may continue to
facilities, be required under
limited use of State policies. The
deterrent systems number of States and
such as streamers the policy details are
and reflectors. unknown. The Solar
Energy Industry
Association is not
aware of any companies
that reduced best
management practices
as a result of the
January 7 rule.
Wind Electric Power Generation Following Wind Likely minimal effects.......... Following the Wind
(221115). Energy Guidelines, Energy Guidelines has
which involve become industry best
conducting risk practice and would
assessments for likely continue. In
siting facilities. addition, the industry
uses these guidelines
to aid in reducing
effects on other
regulated species like
eagles and threatened
and endangered bats.
Electric Bulk Power Transmission Following Avian Likely minimal effects.......... Industry would likely
(221121). Power Line continue to use APLIC
Interaction guidelines to reduce
Committee (APLIC) outages caused by
guidelines. birds and to reduce
the take of eagles,
regulated under the
Bald and Golden Eagle
Protection Act.
Electric Power Distribution Following Avian Likely minimal effects.......... Industry would likely
(221122). Power Line continue to use APLIC
Interaction guidelines to reduce
Committee (APLIC) outages caused by
guidelines. birds and to reduce
the take of eagles,
regulated under the
Bald and Golden Eagle
Protection Act.
Wireless Tele-communications Installation of Likely minimal effects.......... Industry will likely
Carriers (except Satellite) flashing continue to install
(517312). obstruction flashing obstruction
lighting. lighting to save
energy costs and to
comply with recent
Federal Aviation
Administration
Lighting Circular and
Federal Communication
Commission
regulations.
----------------------------------------------------------------------------------------------------------------
We developed an IRFA out of an abundance of caution to ensure that
economic impacts on small entities are fully accounted for in this
rulemaking process and published it for public comment. We considered
those comments and developed a FRFA that can be viewed online at http://www.regulations.gov in Docket No. FWS-HQ-MB-2018-0090. After further
review, we have determined that this rule will not have an impact on a
substantial number of small entities. The January 7 rule was in effect
for less than 1 year, and many comments from industries stated that
they did not make changes in the implementation of best practices in
response to the January 7 rule because they continued to follow various
regulations and guidance (as shown in table 3). The Service expects the
impact of this rule will be minimal because entities did not reduce
best management practices as a result of the January 7 rule excluding
incidental take from the scope of the MBTA. Therefore, we certify that
this rule will not have a significant economic impact on a substantial
number of small entities.
Unfunded Mandates Reform Act
In accordance with the Unfunded Mandates Reform Act (2 U.S.C. 1501
et seq.), we have determined the following:
a. This rule would not ``significantly or uniquely'' affect small
government activities. A small government agency plan is not required.
b. This rule would not produce a Federal mandate on local or State
government or private entities. Therefore, this action is not a
``significant regulatory action'' under the Unfunded Mandates Reform
Act.
Takings
In accordance with E.O. 12630, this rule does not contain a
provision for taking of private property and would not have significant
takings implications. A takings implication assessment is not required.
Federalism
This rule will not create substantial direct effects or compliance
costs on State and local governments or preempt State law. Some States
may choose not to enact changes in their management efforts and
regulatory processes and staffing to develop and or implement State
laws governing birds, likely accruing benefits for States. Therefore,
this rule would not have sufficient federalism effects to warrant
preparation of a federalism summary impact statement under E.O. 13132.
Civil Justice Reform
In accordance with E.O. 12988, we determine that this rule will not
unduly burden the judicial system and meets the requirements of
sections 3(a) and 3(b)(2) of the Order.
Paperwork Reduction Act
This rule does not contain information collection requirements, and
a submission to the Office of Management and Budget (OMB) under the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.) is not
required. We may not conduct or sponsor, and you are not required to
respond to, a collection of information unless it displays a currently
valid OMB control number.
List of Subjects in 50 CFR Part 10
Exports, Fish, Imports, Law enforcement, Plants, Transportation,
Wildlife.
Regulation Removal
For the reasons described in the preamble, we hereby amend
subchapter B of chapter I, title 50 of the Code of Federal Regulations
as set forth below:
PART 10--GENERAL PROVISIONS
0
1. The authority citation for part 10 continues to read as follows:
Authority: 16 U.S.C. 668a-668d, 703-712, 742a-742j-l, 1361-
1384, 1401-1407, 1531-1543, 3371-3378; 18 U.S.C. 42; 19 U.S.C. 1202.
Sec. 10.14 [Amended]
0
2. Remove Sec. 10.14.
Shannon A. Estenoz,
Assistant Secretary for Fish and Wildlife and Parks.
[FR Doc. 2021-21473 Filed 9-30-21; 8:45 am]
BILLING CODE 4333-15-P