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_.lr........-'-"" ...._...-'.._.. ._'. o 0 2 3 ;; 3 . . V.S, Fish and Wildlife Service Resoonse The July 12. 1990, response from the general concurrence with Recommendations Recommendation 3 as follows: Service (Appendix 3) expressed 1 and 2 but nonconcurrence with Recommendation 1. The Service indicated concurrence with the recommendation on multispecies listings but stated that a "600-page listing package is not feasible nor practical." The Service stated that complying with the Act's statutory requirements for analyzing all factors for each species would require a very large commitment of resources such as $1 million in page changes for placing the proposal in the Federal Ree:ister, as well .as a very large staff to analyze the "many thousands" of comments. The Service also stated that the Director has "emphasized the preparation of more multispecies rules" to regional directors and that one region had begun to prepare several listing proposals for some species. The Service further stated that the revised "Listing Handbook" would be distributed by the end of the swruner (1990) and would have extensive guidelines on the "preparation of 'cluster packages.'" Recommendation 2. The Service stated thac it agrees with the need for more status surveys but that the resources needed to complete the surveys "simply have not been available." The Service stated that an alternative approach has been Co encourage more state cooperation and that "individual State Heritage Programs have been under contracts to conduct field surveys for many species in several States." Recommendation 3. The Service stated that it does !lnot support giving the States the responsibility of conserving endangered and threatened endemics in lieu of listing. ,. The Service stated that local and state governments often do not have the legal authority to enforce such protection and that without Federal protection, species are not afforded the benefits of Section 7 consultation. as well as other provisions of the Act. The Service indicated that the states can playa greater role prior to listing and in the recovery of species and that cooperative agreements with state and local governments may provide some short-term protection. The Service concluded that without Federal protection. "it is unlikely that long-term species protection can be realized. " Office of Insoector General Comments The Service's response was sufficient to generally resolve Recommendation 1 but was not sufficient to resolve Recommendations 2 and 3 as follows: Recommendation 1. Although the Service agreed and has initiated actions to take advantage of multispecies listing. it noted that listing all eligible species en masse was neither "feasible nor practical." In our opinion, expeditious listing of all eligible species is a fundamental requirement of the Act. As such, we believe that the Service should officially list all species currently meriting protection under the Act within its funding profile and immediately apprise the Congress of the 9