
The Xerces Society opposes rescission of the definition of “Harm” under the ESA, Docket No. FWS-HQ-ES-2025-003. We respectfully submit the following comments in strong opposition to the proposed rule that would rescind the regulatory definition of “harm” under the Endangered Species Act (ESA). If enacted, this action could undermine implementation of the ESA by creating confusion about its protections and weakening deterrents to habitat destruction.