Section 7 Consultation

Section 7 of the Endangered Species Act (Act) outlines procedures for interagency cooperation to conserve federally listed species and designated critical habitatsSection 7(a)(1) requires federal agencies to use their authorities to further the conservation of listed species.  This section of the Act makes it clear that all federal agencies should participate in the conservation and recovery of listed threatened and endangered species.  Under this provision, federal agencies often enter into partnerships and Memoranda of Understanding with the Fish and Wildlife Service (Service) for implementing and funding conservation agreements, management plans, and recovery plans developed for listed species.  Section 7(a)(2) requires federal agencies to consult with the Service to ensure that they are not undertaking, funding, permitting, or authorizing actions likely to jeopardize the continued existence of listed species or destroy or adversely modify designated critical habitat.  In fulfilling these requirements, each agency must use the best scientific and commercial data available.  This section of the Act defines the consultation process, which is further developed in regulations promulgated at 50 CFR § 402.  Section 7 also establishes the requirement to conduct conferences on proposed species, allows applicants to initiate early consultation, and establishes procedures for seeking exemptions from the requirements of section 7(a)(2) from the Endangered Species Committee.

The consultation process begins when a federal agency or designated non-federal representative requests a species list from the Service, or the verification of a species list by the Service, or when it is determined that a discretionary federal action may affect a listed species or critical habitat.  Most consultations are conducted informally with the federal agency or a designated non-federal representative.  Informal consultation is an optional process that includes all discussions and correspondence between the Service and a federal agency or designated non-federal representative, prior to formal consultation, to determine whether a proposed federal action may affect listed species or critical habitat.  This process allows the federal agency to utilize the Service’s expertise to evaluate the agency’s assessment of potential effects or to suggest possible modifications to the proposed action which could avoid potentially adverse effects.  Informal consultation ends when the federal agency determines that the action would have no effect on listed species or critical habitat or it is determined that the action is not likely to adversely affect listed species or critical habitat and written concurrence of this determination is provided by the Service.

Click here to view the Informal Consultation Process flowchart.

Section 7 Conference

Section 7(a)(4) of the Act provides a mechanism for identifying and resolving potential conflicts between a proposed action and proposed species or proposed critical habitat at an early planning stage.  While a consultation is required when a proposed action may affect listed species or critical habitat, a conference is required only when the proposed action is likely to jeopardize the continued existence of a proposed species or destroy or adversely modify proposed critical habitat.  However, federal action agencies may request a conference on any proposed action that may affect proposed species or proposed critical habitat.  The Service also can request a conference after reviewing available information suggesting a proposed action is likely to jeopardize proposed species or destroy or adversely modify proposed critical habitat.  When both listed and proposed listed species or designated and proposed designated critical habitats are affected by a proposed action, the action agency could include an assessment or evaluation of potential effects to the proposed species or proposed critical habitat during the consultation.

Biological Assessments

The main focus of the consultation is the biological assessment or biological evaluation.  Section 7(c)(1) of the Act requires federal agencies to prepare a biological assessment if any listed species may be present in the action area or for major construction activities, which are considered to be federal actions significantly affecting the quality of the human environment as referred to in the National Environmental Policy Act of 1969 (NEPA)(42 U.S.C. 4321 et seq.).  The contents of the biological assessment are discretionary, but should include all necessary information to determine the likelihood of the presence of listed species (on-site inspections, habitat surveys, literature review, etc.), an analysis of all potential effects (including direct, indirect, and cumulative effects) to listed species, and a determination of the proposed actions effects to listed species.

The effect determination should be a logical resolution justified by the analysis and consist of one of three choices: 1) no effect, 2) is not likely to adversely affect, and 3) is likely to adversely affect.  A "no effect" determination is suitable for those actions that are anticipated to have no adverse effects to listed species or critical habitat.  An "is not likely to adversely affect" determination is the appropriate conclusion when effects on listed species or critical habitat are expected to be discountable, insignificant, or completely beneficial.  An "is not likely to adversely affect" determination requires written concurrence from the Service.  An "is likely to adversely affect" determination is the appropriate conclusion if any adverse effect to listed species of critical habitat may occur as a direct or indirect result of a proposed action or its interrelated or interdependent actions, and the effect is not: discountable, insignificant, or beneficial.  An "is likely to adversely affect" determination requires formal consultation.

Federal agencies are not required to prepare a biological assessment for actions that are not major construction activities, however, if the action "may affect" listed species or critical habitat, the agency must provide the Service with an account of the basis for evaluating the likely effects of the action.  This documentation is necessary for the Service to decide if concurrence with the agency’s determination is warranted.  For this reason, the Service recommends a biological evaluation be prepared for all actions that are not major construction activities, but that may affect listed species or critical habitat and Service concurrence is required.  A biological evaluation should follow the same guidelines as a biological assessment and include all relevant information for justifying the effect determination.  For those evaluations that conclude that no effects to listed species or critical habitat are anticipated, section 7 consultation is not necessary.