Remember those proposed rules that would weaken the Endangered Species Act? You know, the ones that generated hundreds of thousands of comments from concerned citizens? Well, it looks like the Bush Administration isn’t going let the pesky task of actually considering those comments get in the way of its zeal to finalize its proposal its time in power ends.
The AP has obtained an internal e-mail from Brian Aroyyo, the U.S. Fish and Wildlife Service’s Assistant Director for the Endangered Species Program, that the agency is attempting to review 200,000 substantive comments from the public “in just 32 hours.” According to the AP, that works out to roughly 9 seconds per comment.
In fairness, the AP story also states that the Fish and Wildlife Service’s team’s task will be “to sort through the comments” and that “Interior Secretary Dirk Kempthorne's office, according to the e-mail, will be responsible for analyzing and responding to them.” So it may be that some comments get more than their 9 seconds worth.
Having the Department of Interior, rather than the Fish and Wildlife Service, respond to the comments is consistent with some informal conversations I’ve had with Agency personnel, who told me that the scientists and policy experts at the Fish and Wildlife Service were not consulted on these proposed rule changes and would not be taking any role in analyzing them. Reading between the lines a bit, it sounded to me that the Service’s career employees were none to happy about the proposal or the Administration’s failure to run it through normal channels. Put another way, these rule changes are almost entirely the product of political appointees at the Department of the Interior and it looks like the Bush Administration is determined to keep it that way.
One other thing jumped out at me about the AP story. The article quotes Dale Hall, the Director of the Fish and Wildlife Service as stating that
The Interior Department received approximately 300,000 comments over the 60-day comment period, many critical of the changes.
About 100,000 of them were form letters, Hall said
This is strange. First, how could Director Hall possibly know that 100,000 of the 300,000 comments his agency received were form letters if they haven’t been reviewed yet? While it’s true that the NRDC Action Fund and its environmental allies delivered 100,000 comments to the agency, not all of them were form letters; in many cases, Action Fund supporters customized their letters. These comments deserve just as careful a review as any other. And, even if it’s true that 100,000 form comments were received, that means there are at least 200,000 substantive comments that need to be “sorted” by the Fish and Wildlife Service and analyzed by the Department of the Interior.
The final piece of the puzzle is this: according to Hall, the goal of this rushed process is to get to have the rule to the White House by early November. It’s pretty hard to conclude that the public’s input on these proposed regulations—regulations that will weaken one of America’s bedrock environmental laws—will be given anything but the shortest of shrifts—if the Administration is going to meet its goal.