The working materials in the NRDC Document Bank are listed in reverse chronological order. For additional policy materials including reports and issue papers, see the Issues section of the main NRDC site.
NRDC letter re Asplund facility 301(h) waiver in Cook Inlet, Alaska
Comments from NRDC urging EPA to deny the John M. Asplund Wastewater Treatment Facility’s application for a 301(h) waiver under the Clean Water Act and require the facility to upgrade to full secondary treatment. Operating under a waiver that’s been administratively continued since 2005, the Asplund facility discharges primary treated sewage into critical habitat for endangered Cook Inlet beluga whales. Reauthorization of the facility’s 301(h) waiver would violate the Clean Water Act, Endangered Species Act, Marine Mammal Protection Act, and state and federal antidegredation requirements.
Shell Drilling Arctic Complaint
Complaint filed to protect Pacific walruses from Shell drilling in the Arctic.
Report on the Status of the Monarch Butterfly Migration
Report on the status of the monarch butterfly migration and petition to include the Monarch Butterfly Biosphere Reserve in Mexico on the List of World Heritage in Danger, April 2015.
- wil_15040901b.pdf Informe sobre el estado de la migración de la mariposa monarca y solicitud para incluir la Reserva de la Biósfera Mariposa Monarca en la Lista del Patrimonio Mundial en Peligro, Abril 2015.
HI District Court Order Granting Order for Summary Judgment 3-31-15
The District Court of Hawaii's amended order granting NRDC's motion for summary judgment, a victory in the fight against the Navy’s use of harmful sonar.
Letter to the State of Montana and Yellowstone National Park Regarding New Yellowstone Bison Management Plan
Joint letter from conservation organizations to the State of Montana and Yellowstone National Park regarding the development of a new Yellowstone bison management plan, March 13, 2015.
Letter to President on seismic oil and gas exploration in the U.S. mid-Atlantic and south Atlantic coasts.
Letter to the President regarding concern over the introduction of seismic oil and gas exploration along the U.S. mid-Atlantic and south Atlantic coasts.
Complaint for Declaratory and Injunctive Relief against the U.S. Environmental Protection Agency
The Natural Resources Defense Council (NRDC) has filed a lawsuit against the U.S. Environmental Protection Agency (EPA) for failing to respond to NRDC’s February 2014 petition requesting urgent review of glyphosate-containing pesticides in light of serious harms to monarch butterflies. In its petition, NRDC presented EPA with substantial scientific evidence of glyphosate’s devastating impact on monarchs and requested EPA to restrict the use of glyphosate-containing pesticides, or impose other mitigation measures, to prevent unreasonable adverse effects to the monarch butterfly. A year later, EPA has yet to respond to NRDC’s petition. As set forth in this complaint, NRDC seeks to compel EPA to respond to the petition and to initiate review of glyphosate-containing pesticides.
NRDC Brief and Comments regarding Pebble Mine / Bristol Bay, 2012-2014
NRDC Briefs and Comments regarding Pebble Mine / Bristol Bay, 2012-2014
- wil_15012901a.pdf Brief on Behalf of the Natural Resources Defense Council in Support of Petitions to the U.S. Environmental Protection Agency for Action Regarding the Proposed Pebble Mine Under Section 404(c) of the Federal Water Pollution Control Act, March 28, 2012
- wil_15012901b.pdf Comments on Behalf of the Natural Resources Defense Council on the U.S. Environmental Protection Agency Draft Bristol Bay Watershed Assessment, July 23, 2012
- wil_15012901c.pdf Comments on Behalf of the Natural Resources Defense Council on the U.S. Environmental Protection Agency Second Draft Bristol Bay Watershed Assessment, June 28, 2013
- wil_15012901d.pdf Comments on Behalf of the Natural Resources Defense Council on the U.S. Environmental Protection Agency’s Proposed Determination to Restrict the Use of an Area as a Disposal Site; Pebble Deposit Area, Southwest Alaska, September 18, 2014
Elephant Ivory Trafficking in California, USA
Report prepared for NRDC examining the ivory trade in California under current state and federal laws, January 2015.
Petition to list the Gulf of Mexico’s Bryde’s whale as an endangered species
The small, resident population of Bryde’s whale (Balaenoptera edeni) in the Gulf of Mexico is a unique subspecies with fewer than 50 animals. The population faces a suite of potential threats in the Gulf’s industrialized waters, along with the population’s extremely small abundance, low genetic diversity, apparently limited range, and exposure to numerous anthropogenic threats, leave it highly vulnerable to extinction. The Gulf of Mexico Bryde’s whale qualifies as a distinct population segment and, given its vulnerability, must be listed as an endangered species under the Endangered Species Act.
Rusty Patched Petition
Petition to list rusty patched bumble bee as endangered.
Rusty Patched Complaint
Complaint filed in ESA deadline suit to list as endangered the rusty patched bumble bee.
IMO Guidelines for the Reduction of Underwater Noise
Guidelines from the International Maritime Organization for the reduction of underwater noise from commercial shipping, to address adverse impacts on marine life.
Petition to Conduct Interim Administrative Review for the Pesticide Glyphosate, in Light of Serious Harm to Monarch Butterflies
NRDC is petitioning EPA under FIFRA to undertake urgent interim administrative review for glyphosate, and to restrict the pesticide’s uses and/or impose other necessary mitigation measures, to prevent unreasonable adverse effects to the monarch butterfly. As discussed in the petition, the agency should moreover ensure that imposing restrictions on glyphosate use does not lead to increased use of other herbicides that may be equally harmful to monarchs, and that may pose health risks.
NRDC Petition to List the Tufted Puffin Under the Endangered Species Act
NRDC submitted a petition on February 12, 2014 to the U.S. Fish and Wildlife Service seeking Endangered Species Act listing for the California, Oregon, and Washington population of the tufted puffin, a seabird well-known for its distinctive facial coloring and plumage during the breeding season.
NRDC Comment Letter Regarding Montana Wolf Management Rule Changes
This letter details NRDC’s concerns regarding Montana’s proposal to amend its wolf management rules. NRDC opposes many of the proposed amendments because they would increase the number of wolves and other species trapped, shot and killed by landowners on private property.
Comments Regarding Proposed Rules to Remove the Gray Wolf from the List of Threatened and Endangered Species
Comments sent to the U.S. Fish and Wildlife Services on December 16, 2013 regarding proposed rules to remove the gray wolf from the List of Threatened and Endangered Species.
Letter to APHIS regarding bumble bees
A letter to APHIS regarding a petition to regulate the movement of commercial bumble bees.
Letter from Representatives Peters, DeFazio, and Campbell calling on the USDA's Inspector General to Investigate and Audit USDA Wildlife Services
Letter from Representatives Peters, DeFazio, and Campbell calling on the USDA’s Inspector General to Investigate and Audit USDA Wildlife Services
New Science On Impacts of Navy Sonar
A letter to the California Coastal Commission that details recent scientific studies, which confirm the harmful impacts of Navy sonar training and testing on Southern California marine mammals.
New Facts and Additional Information Supporting the CoP16 Polar Bear Proposal Submitted by the United States of America
The United States proposes to transfer the polar bear, Ursus maritimus, from Appendix II to Appendix I of the Convention on International Trade in Endangered Species (CITES), on the basis that the polar bear is affected by trade and threatened with extinction because of a projected marked decline in the population size in the wild. This paper summarizes new scientific findings and additional evidence since 2009, which underpin Russian Federation and U.S. support for uplisting since the last Convention was held. Notably, the reasons why polar bears meet the criteria for Appendix I listing are (1) they are a species that has declined in the wild, and is characterized by future declines, leading to widespread extirpation, projected on the basis of a decrease in area and quality of habitat; and (2) they are a species affected by commercial trade, which overharvesting is helping supply.
Comments on Mammal Damage Management in the Commonwealth of Virginia Environmental Assessment
NRDC letter comments on Wildlife Services' draft Environmental Assessment evaluating the impacts of alternatives for mammal damage management in Virginia, and urges Wildlife Services to withdraw the Draft EA and instead prepare an environmental impact statement (“EIS”).
CEO Green Group Pebble Mine Letter (July 23)
A coalition letter from various green groups to EPA in support of its Draft Watershed Assessment’s findings that large-scale mining would cause irreparable harm to the Bristol Bay watershed.
Environmental Entrepreneurs letter to EPA re Watershed Assessment
A letter from E2 to EPA in support of its Draft Watershed Assessment’s findings that large-scale mining would cause irreparable harm to the Bristol Bay watershed.
NRDC Cover Letter re EPA Watershed Assessment Comments (July 23 2012)
NRDC’s cover letter associated with our comments on EPA’s Draft Watershed Assessment of Bristol Bay and the potential impacts of large-scale mining there, particularly the Pebble Mine.
NRDC Comments on EPA Watershed Assessment July 23 2012
NRDC’s comments on EPA’s Draft Watershed Assessment of Bristol Bay and the potential impacts of large-scale mining there, particularly the Pebble Mine.
Legal brief regarding the proposed Pebble Mine in Alaska
Brief on Behalf of the Natural Resources Defense Council in Support of Petitions to the U.S. Environmental Protection Agency for Action Regarding the Proposed Pebble Mine Under Section 404(c) of the Federal Water Pollution Control Act.
National and Alaska Survey on Pebble Mine
A national poll reveals solid opposition to Pebble Mine, proposed at the headwaters of Bristol Bay, Alaska. Protecting salmon – and the jobs, people, and wildlife that depend on it – from the mine’s projected 10 billion tons of waste are the leading causes of opposition for both residents in the lower 48 states and Alaska.
Oppose the Extinction Rider
The Interior and Environment Appropriations bill for FY12 contains a rider (p. 8) that would prevent the Fish and Wildlife Service from listing any new species or designating critical habitat for any currently listed species under the Endangered Species Act. The rider does allow the Fish and Wildlife Service to delist and downlist species, thus creating a one-way ratchet in which wildlife protection can only be weakened.
Oppose Provisions that Harm Bighorn Sheep
The Interior and Environment Appropriations bill for FY12 contains two riders (sections 120 & 442) that would allow domestic sheep in the west to graze without restrictions in order to appease a handful of ranchers in Idaho. This would make domestic sheep more likely to come into contact with and spread deadly diseases to bighorn sheep.
Protect Endangered Species from Harmful Pesticides
The Interior and Environment Appropriations bill for FY12 contains a rider (section 447) offered by Rep. Calvert (R-CA) that would prevent EPA from implementing measures to mitigate the effects of harmful pesticides on endangered and threatened species, as required under the Endangered Species Act.
Oppose a Provision That Would Remove Courts from the Endangered Species Act Process
The Interior and Environment Appropriations bill for FY12 contains a rider (section 119) that would shield potentially flawed wolf delisting decisions in Wyoming and the Great Lakes from judicial review.
Green Group CEOs letter to President Obama emphasizing the need to include revenues in a debt limit agreement
Letter from Green Group CEOs to President Obama as debt ceiling negotiations continue, emphasizing the need to include revenues in any debt limit agreement. The letter points out that dealing with the deficit without raising significant additional revenues is quite simply a decision to dismember vital programs on which the public depends, including those that protect health and the environment, provide for conservation and recreation, and maintain critical infrastructure.
Comments on the U.S. Fish and Wildlife Service's Proposals Affecting Wolves
NRDC supports the delisting of gray wolves in the Midwest, including in Minnesota, Wisconsin and Michigan. However, NRDC does not believe that the best available scientific evidence supports the recognition of Canis lycaon as a species. Additionally, the proposed reclassification of many wolves occurring in the Midwest and all wolves in the northeastern United States, as Canis lycaon is unnecessary at this time and undermines the Service’s delisting proposal for Midwest wolves. Finally, NRDC strongly urges the Service to recognize and list a Distinct Population Segment of wolves in the Pacific Northwest.
Letter in support of shark species preservation
This letter in support of Assembly Bill 376 is dated June 24, 2011 and was sent to the members of the California State Senate Natural Resources and Water Committee. The letter is signed by Wayne Pacelle, President and CEO of The Humane Society; Peter Knights, Executive Director of WildAID; Frances Beinecke, President of NRDC; and Leonardo DiCaprio, Actor/Activist.
Coalition Letter to Christopher C. Ward regarding JFK expansion
Letter dated March 17, 2011 in opposition to proposal to expand JFK Airport into Jamaica Bay to Christopher O. Ward
NRDC Comments on Wolf Management in Idaho
Comments on Wildlife Services' Revised Environmental Assessment evaluating the impacts of alternatives for gray wolf damage management in Idaho.
Notice of Appeal for FirstEnergy BayShore Plant, 12/17/2010
Five groups are appealing pollution permits for a coal plant in Lake Erie’s Maumee Bay that currently kills 60 billion fish on the grounds that the State of Ohio is not requiring the best available technology to eliminate the problem as required by law.
Idaho Wolf EA Comments
NRDC's Montana office submitted comments on the USDA’s Wildlife Services agency’s environmental assessment process evaluating the impacts of "alternatives for gray wolf damage management in Idaho."
Federal Endangered Species Act Protections for Gray Wolves in the Northern Rockies Restored
Legal decision restoring federal Endangered Species Act protections for gray wolves in the Northern Rockies filed August 5, 2010.
Great Lakes NGO Whitehouse Letter on Asian Carp
Some of the most prominent National and Great Lakes conservation groups have petitioned President Obama to step in and make significant changes to the federal response to the ongoing Asian carp crisis.
NRDC Comments on the Montana Wolf Hunt - 2010
Wolf hunts in the Northern Rockies threaten to undermine one of the greatest conservation successes in history. Wolf populations in the region have come very close to reaching sustainable levels, however state managed hunts may prevent populations from reaching those levels, particularly given the way the hunts were managed in the first year. NRDC submitted comments on the hunts.
A Grizzly Challenge: Ensuring a Future for Alberta's Threatened Grizzlies
This joint report from the David Suzuki Foundation, NRDC, Yellowstone to Yukon and a variety of other interested groups looks at the shaky future faced by Alberta’s shrinking grizzly bear population.
NRDC and Gulf Coast Community Letter to Department of Labor
Letter requests U.S. Department of Labor to take specific steps to protect the health of fishermen and workers working in oil-contaminated areas post BP oil spill.
Letter from NRDC President Frances Beinecke to President Obama regarding scope of independent investigation of Gulf oil disaster.
The letter to the President recommends that the independent commission being established by the President be given a broad mandate to investigate the causes of the Gulf oil disaster spill, the adequacy of the response, the regulatory changes needed to protect the environment and prevent such a disaster in the future and the implications of its findings for determining the location and extent of future offshore drilling.
NRDC Comments on the Draft Proposed Outer Continental Shelf (OCS) Oil and Gas Leasing Program, 2010-2015, (January, 2009)
This letter from September 21, 2009, to the Minerals Management Service (MMS) of the Department of Interior (the Department, Interior, or DOI), comments on the Draft Proposed Outer Continental Shelf (OCS) Oil and Gas Leasing Program, 2010-2015.
Ensuring a Future for Canada's Grizzly Bears
This joint report from the David Suzuki Foundation and NRDC looks at the dangerous impacts of excessive grizzly bear trophy hunting in Canadian national parks. The death toll affects populations on both sides of the national border, as many bears move between protected areas in the United States and parts of B.C., where most Americans would be surprised to learn that the bears are not protected from trophy hunters, even in provincial parks.
Cross-Border Flathead Region Grizzly Kills Map
NRDC and the David Suzuki Foundation have released a new report detailing trophy hunting of grizzly bears in along the U.S. and Canadian border. This map details kills observed in the British Columbia portion of the Flathead region.
Comments on Minnesota's Special Registration Review for the Pesticide Atrazine
These comments complement NRDC’s national report, Poisoning the Well, on the impact of atrazine on surface and drinking water in the Midwest, including Minnesota. (Wu et al., 2009.)
Protecting the Great Lakes: Keeping ballast water pollution out of New York
NRDC argued on behalf of New York’s aggressive new state law to keep invasive species out of the Great Lakes by putting limitations on the dumping of ballast water from cargo ships. The Appellate Division of the Supreme Court of New York in Albany sided with NRDC and NWF when they intervened in the Port of Oswego Authority vs. Grainis case.
Bee Toxic Pesticide Pulled from the Market
This federal court decision was a win for bees when NRDC challenged an illegal registration for the highly toxic insecticide, spirotetramat (trade named Movento). The court agreed with NRDC’s argument that regulators had not followed basic procedures for allowing public comment and evaluating the chemical’s economic, environmental, and social impacts. The chemical will be removed from American store shelves until it has been appropriately evaluated.
Petition to List Atlantic Sturgeon as Endangered Under the Endangered Species Act
NRDC’s petition to list the Atlantic sturgeon as an endangered species throughout all or a significant portion of its range pursuant to the federal Endangered Species Act ("ESA").
Petition to List the Insular Population of Hawaiian False Killer Whales as Endangered Under the ESA
NRDC petitions the Secretary of Commerce through the National Marine Fisheries Service to add the Hawaiian false killer whale population to the endangered species list. The Hawaiian false killer whale population is a small and ecologically unique population of 120 animals that has suffered a significant decline over the last 25 years.
Order Granting Preliminary Injunction to Restore Wolf Protections
This opinion, issued by Federal District Judge Donald Molloy on Friday, July 18, 2008, orders the U.S. Fish and Wildlife Service to restore federal Endangered Species Act protections to the Northern Rocky Mountain population of gray wolves pending the resolution of a lawsuit, brought by NRDC and our allies, challenging the Bush Administration's decision to strip the region's wolves of their federal protection.
Petition to File a Gray Wolf Recovery Plan
NRDC and Defenders of Wildlife filed this February 2008 petition to the U.S. Fish and Wildlife Service to prepare a recovery plan for the gray wolf under the Endangered Species Act.
Department of Interior Letter to Wyoming Fish and Game – January 2004
This letter was sent to the State of Wyoming noting that significant concerns over the state’s wolf management plan could affect the effort to remove wolves from the Endangered Species List and that the Wyoming wolves could not be separated from the larger Northern Rockies population that also includes animals in Idaho and Montana.