Dear Mr. Berg:

On December 20, 2013, the U.S. Fish & Wildlife Service ("FWS") published a revision to the final rule that listed the White Bluffs bladderpod, Physaria Douglasii subspecies Tuplashensis, as a threatened species under the Endangered Species Act ("ESA") and designated over 2,000 acres as critical habitat. The White Bluffs bladderpod was one of the many species included in the 2011 closed-door settlement between the FWS and the Center for Biological Diversity ("CBD"), which arbitrarily established a deadline of 2013 for the FWS to decide whether to list the White Bluffs bladderpod as a protected species. Based on the Service's handling of the bladderpod listing, it appears that this deadline, rather than quality data and science, drove the listing and critical habitat decision.

Read the entire letter HERE.