
The ESA should be amended in a manner that:
1. Expressly states that existing, approved HCPs are exempt from critical habitat designation overlays.
2. Provides for immediate elimination of critical habitat designations within an HCP, once the HCP is approved and finalized. While it is our belief that the Service can take this approach with respect to future HCPs under existing law, the Service disagrees thus requiring the need for a legislative solution.
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