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Field Observations:

The Section 7 Training Blog

Tips and Techniques
The Current Administration’s Broader Approach to Emergency Consultation
Shortly after the energy emergency declaration, a document was released in April 2025 titled “ALTERNATIVE PROCEDURES FOR INFORMAL SECTION 7 CONSULTATION” describing alternative procedures set out by the Acting Director of the Fish and Wildlife Service (Paul Souza)... the idea by the administration is to use these procedures to reduce perceived delays in the consultation timeline.
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Programmatic Consultations
Though the development and use of programmatic consultations has been part of the consultation practice for at least 35 years, guidance on how to approach these programmatic consultations has been minimal. This has resulted in many non-standard approaches to construction and to naming conventions for programmatics - creating a good deal of confusion over the subject.... For all these reasons, I am building a course dedicated to clearing some of the confusion around these programmatic approaches and describing a process that action agencies and the Services can use to make them more likely to succeed.
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7(d) and Irreversible or Irretrievable Commitment of Resources During Section 7 Consultation
The purpose of section 7(d) is to preserve options in case the consultation eventually concludes that the proposed project is likely to jeopardize a listed species or is likely to result in the destruction or adverse modification of designated critical habitat.
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Emergency Consultation
Practitioners often have questions about emergency consultations because they usually occur under somewhat chaotic circumstances and don't follow the normal process that non-emergency consultations do... so I've boiled down emergency consultations to a couple of key thoughts...
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