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Fish and Wildlife Service Proposes to Restore Incidental Take Prohibition Under Migratory Bird ‎Treaty Act – What You Need to Know

On May 7, 2021, the U.S. Fish and Wildlife Service (“USFWS” or “Service”) published a proposed rule that would restore the traditional interpretation of the Migratory Bird Treaty Act (“MBTA”) as prohibiting incidental take...more

The Regulatory Resurrection of M-37050:‎ Interior Rule Limits the MBTA Again, But Likely Not for Long

On January 7, the Department of the Interior (“DOI”) published a final rule codifying its previously announced interpretation that the Migratory Bird Treaty Act (“MBTA”) applies only to intentional acts directed at migratory...more

Trump Administration’s MBTA M-Opinion Vacated: What You Need to Know

The Migratory Bird Treaty Act (“MBTA”) was first adopted in 1918, and for most of its existence the Department of the Interior (“DOI”) interpreted it to prohibit any taking or killing of migratory birds, intentional or not. ...more

USFWS Guidance Implementing Solicitor’s M-Opinion Finally Grounds the Migratory Bird Treaty Act

On December 22, 2017 the U.S. Department of the Interior’s (“DOI”) Office of the Solicitor issued Memorandum M-370501 (the “M-Opinion”) interpreting the take prohibition of the Migratory Bird Treaty Act2 (“MBTA”) to apply...more

Fifth Circuit Holds that Migratory Bird Treaty Act Does Not Apply to Incidental Takes - What It Means for Energy Developers

On September 4, 2015, the Fifth Circuit Court of Appeals reversed the misdemeanor convictions of Citgo Petroleum Corporation and Citgo Refining and Chemicals Company, L.P. (collectively Citgo) for “taking” migratory birds in...more

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