Article: There's something fishy going on here: a critique of the National Marine Fisheries Service's definition of species under the Endangered Species Act. (Endangered Species Act at Twenty-One: Issues of Reauthorization)

I. INTRODUCTION

Even after all of the controversy and litigation spawned by the federal Endangered Species Act of 1973 (ESA),(1) it is ironic that over twenty years after its enactment agencies which administer the Act lack a clear sense of what "species" they should protect. The National Marine Fisheries Service (NMFS), which together with the U.S. Fish and Wildlife Service (FWS) is charged with implementing the statute,(2) recently attempted to define populations which qualify for listing.(3) In a recent law review article,(4) attorneys with NMFS and the National Oceanic and Atmospheric Administration (NOAA) explained the agency's rationale for its ...

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