Reply #5: My response:

[patriotvoice]

"The spirit of the ESA as enacted is to broadly protect the interest (habitat, food sources, and generative capability) of species uniquely and culturally valuable to all citizens of the United States. The proposed definition changes run afoul of this spirit.

Specifically, the proposed definition change for "Cumulative effects" gives Federal authorities significantly more latitude in the projects they may entertain, while silently limiting similar projects at the state or private levels. (FR 73 159 S402.02 allows Federal activities that would be prohibited if initiated by State or private concerns.) That is wholly unacceptable: Federal authorities must be MORE cautious, not less, as their effects are wider reaching.

More odiously, the proposed definition change for "effects of action" side-steps the complexity of environmental interaction and will, if enacted, render the ESA essentially void. Decades of research shows that species collapse occurs because of systemic failure -- from systemic causes -- not essential failures from essential causes. Once again, the proposed definition loosens the Federal responsibility to take reasonable measures to protect an endangered species. And again, this is wholly unacceptable: Federal authorities must be MORE cautious, not less."