This proposal fails to…

This proposal fails to adhere to the requirements of an Overall Benefit Permit and and such should not be allowed. This plan does not provide any information that meets the conditions standards as laid out by the permit. There is no stated impact or assessment monitoring, 2 required conditions. The plan as set out also fails a requirement portion of permit.

"Providing an overall benefit to a species means undertaking actions that contribute to improving the circumstances for the species. It must include more than steps to minimize adverse effects on the species or habitats."

The above quote is directly from the Overall Benefit Permit. This proposal is nothing more than imprecise and indistinct steps to with the goal of minimizing adverse effects. This proposal fails to meet the quoted criterion. There is not even specification regarding where the butternut individuals will be planted. The proposal is devoid of detail and specificity.

This proposal for an Overall Benefit Permit is deficient and fails to adhere to the conditions and requirements of the permit. This plan in no way meets the burden required to prove an overall benefit to the butternut will be achieved. As such, there is no way that this permit can be given without violating the Endangered Species Act and the ethical standards of the Overall Benefit Permit. This proposal must be rejected.