Mar 312015

The resolution supporting delisting is below.

Here's the press release about the meeting, held this past weekend.

Restoring State Management of the Gray Wolf in the Western Great Lakes States

WHEREAS, the National Wildlife Federation is a strong supporter of scientific and professional management of wildlife species including the recovery of the gray wolf under the federal and state Endangered Species Acts; and

WHEREAS, gray wolf populations in Minnesota, Michigan and Wisconsin have exceeded their recovery targets by a factor of ten; and

WHEREAS, the Minnesota, Michigan and Wisconsin Departments of Natural Resources developed wolf management recovery plans that were approved by the U.S. Fish and Wildlife Service and were successfully implemented by the respective state agencies; and

WHEREAS, as a result of this successful restoration of the gray wolf in the Western Great Lakes, the U.S. Fish and Wildlife Service, by federal rule, attempted to delist the gray wolf in the states of Minnesota, Michigan and Wisconsin four times between 2003 and 2011; and

WHEREAS, each such delisting of the gray wolf was challenged in Federal Court on technical grounds, not based on its recovery status but on administrative or legal technicalities, which resulted in Federal Court decisions returning the gray wolf to the Federal Endangered Species list and removing state management of the species; and

WHEREAS, the latest Federal Court decision relisting the gray wolf on the Federal Endangered Species list occurred on December 19, 2014 with the court ruling that the gray wolf could not be removed from the Federal Endangered Species list until it had been fully recovered in its full historic range in 29 Eastern and Central states; and

WHEREAS, as a result of this latest court decision, state permits authorizing lethal control of wolves depredating livestock are no longer authorized, state laws authorizing land owners to kill wolves in the act of attacking domestic animals are no longer valid and state laws allowing management of wolf populations through harvest regulation no longer are valid; and

WHEREAS, based on recent and extensive experience, without state lethal methods of management, wolves will continue to cause significant depredation of domestic animals in the states of Minnesota, Michigan and Wisconsin; and

NOW, THEREFORE, BE IT RESOLVED, that the National Wildlife Federation, at its annual meeting assembled March 27-29, 2015 in Shepherdstown, West Virginia, hereby supports the delisting of the gray wolf in the states of Minnesota, Michigan and Wisconsin consistent with the professional scientific judgment of the U.S. Fish and Wildlife Service.

Mar 302015

Comments nonetheless requested on "interim final revised rules"

From the Public Inspection transom comes this: USDA, DOI and NOAA are issuing new rules for resolving factual disputes over conditions in FERC hydro licenses. Got all that?

Hydro rule from NOAA, USDA, Interior: "The Departments of Agriculture, the Interior, and Commerce are jointly revising the procedures they established in November 2005 for expedited trial-type hearings required by the Energy Policy Act of 2005. The hearings are conducted to expeditiously resolve disputed issues of material fact with respect to conditions or prescriptions developed for inclusion in a hydropower license issued by the Federal Energy Regulatory Commission under the Federal Power Act. The Departments are also revising the procedures for considering alternative conditions and prescriptions submitted by a party to a license proceeding."

The Departments are promulgating three substantially similar rules—one for each agency—with a common preamble. The rules and preamble address a few issues that were left open in the 2005 rulemaking, such as who has the burden of proof in a trial-type hearing and whether a trial-type hearing is an administrative remedy that a party must exhaust before challenging conditions or prescriptions in court. In addition, the rules and preamble respond to the public comments we received on the 2005 rules, and they make a number of changes reflecting our experience in implementing those rules.


Matters of policy are also not appropriate for a trial-type hearing. Examples of such matters include what types and levels of adverse effects to a species from a project would be “acceptable,” or what kinds of mitigation measures may be desirable or “necessary” to protect a resource. These are not matters of fact, but rather matters of policy judgment committed to the discretion of the  Departments, in light of their management objectives for the resource. Under EPAct and these regulations, the Departments retain the prerogative to make these ultimate decisions in light of their policies; the ALJ may not appropriately address those issues. See 7 CFR 1.660(b)(3), 43 CFR 45.60(b)(3), 50 CFR 221.60(b)(3).

Related?: Press release from last week: 'The U.S. Department of Energy, U.S. Department of the Interior and U.S. Department of the Army for Civil Works announced today that the three agencies have extended their partnership to advance hydropower development for an additional five years."


Black rhino trophies to be imported

 Posted by on March 29, 2015
Mar 292015

The Fish and Wildlife Service has allowed the import of two sport-hunted black rhinoceros trophies from Namibia, finding that the decision "will benefit conservation of the species, while the import of any elephant sport-hunted trophy from Zimbabwe will not."

The announcement came Thursday. "The black rhino hunts associated with the imports of two sport-hunted trophies are consistent with the conservation strategy of Namibia, a country whose rhino population is steadily increasing, and will generate a combined total of $550,000 for wildlife conservation, anti-poaching efforts and community development programs in Namibia," the service said.

"In contrast to Namibia’s exemplary management and conservation program for black rhinos, Zimbabwe’s elephant management plan primarily consists of two outdated documents that lack information on their implementation and the progress made toward meeting stated goals and objective," FWS added.

The Namibia decision was criticized by conservationists, who vowed to sue to block future import permits. The permit was auctioned off by the Dallas Safari Club, which generated a fair amount of publicity.

Dallas Safari Club

Mar 272015

Yes, as it says above and below, FWS has awarded more than $4 million in grants to tribes for conservation work.

Here's the text of the press release:

Tribes in 13 states receive $4.2 M from service for conservation work

March 27, 2015

Contact(s):  Christina Meister,, (703) 358-2284

The U.S. Fish and Wildlife Service today announced nearly $4.2 million in Tribal Wildlife Grants to Native American Tribes in 13 states. The awards will support 22 fish and wildlife conservation projects that benefit a wide range of wildlife and habitat, including species of Native American cultural or traditional importance and species that are not hunted or fished.

“Tribal lands encompass millions of acres of important habitat for hundreds of wildlife species across the nation,” said Service Director Dan Ashe. “Tribal Wildlife Grants give us an opportunity for federal and state agencies to work with tribal fish and wildlife partners in the conservation of our shared and highly valued natural heritage; a heritage that we will pass on to future generations of all Americans.”

Since its inception in 2003, the competitive Tribal Wildlife Grants program has awarded more than $68 million to Native American tribes, providing support for more than 400 conservation projects. The funds have also provided technical and financial assistance for development and implementation of projects that benefit fish and wildlife and their habitats, including non-game species.

The grants have enabled tribes to develop increased management capacity, improve and enhance relationships with conservation partners, address cultural and environmental priorities and help train the next generation of conservationists by engaging tribal students interested in fisheries, wildlife and related fields of study.  Some grants have been awarded to support recovery efforts for federally listed threatened and endangered species.

The grants are provided exclusively to federally recognized Indian tribal governments, and are made possible under the Related Agencies Appropriations Act of 2002 through the State and Tribal Wildlife Grants Program. Proposals for the 2016 grant cycle are due October 30, 2015.

For additional information about Native American conservation projects and the Tribal Wildlife Grants application process, visit

 FY 2015 Tribal Wildlife Grants

Telida Village Council ($200,000)
Monitoring Moose for Heavy Metals

Tyonek Tribal Conservation District ($200,000)
Old Tyonek Creek Fish Passage

Gila River Indian Community ($195,854)
Start-Up Wildlife Management Program

Pasque Yaqui Tribe of AZ ($148,660)
Our River, Our Lives:  Stabilizing & Recovering Threatened and Endangered Native Fish Species in the Upper Rio Yaqui Basin

Yavapai-Apache Nation ($82,000)
Verde River Habitat Enhancement Project


Chemehuevi Indian Tribe ($200,000)

The Clear Bay Southwestern Willow Flycatcher and Least Bell’s Vireo Habitat Restoration Project will restore, enhance, and protect 20 acres of priority riparian habitat in Clear Bay along the Colorado River for the benefit of fish and wildlife including the southwestern willow flycatcher, least Bell’s vireo and Yuma clapper rail.

Blue Lake Rancheria ($159,275)

The Powers Creek Fish Passage Project will remove a fish passage barrier and restore over one mile of upstream spawning and rearing habitat in Powers Creek, a small tributary to the Mad River. This project will benefit culturally important threatened and declining species including Southern Oregon/Northern California Coasts coho salmon, California Coastal Chinook salmon, Northern California steelhead trout, and Pacific lamprey

Pinoleville Pomo Nation ($198,905)

Restoration of Ackerman Creek as Habitat for Culturally Important Species proposes to restore habitat for culturally important species through a combination of in-stream restoration projects, pollution prevention and revegetation in Ackerman Creek a tributary to the Russian River. This project will benefit steelhead and salmon and locally endemic insects, amphibians, birds and mammals.

Yurok Tribe ($176,771)

The Northern California Condor Program Building Capacity for a Pilot Release grant will initiate and manage a pilot release of California condors into their former northern range of California. This project will support specific goals of the California Condor Recovery Plan.

Ute Mountain Ute Tribe ($200,000)
Capacity Building for Wildlife Management

Seminole Tribe of Florida ($200,000)
Seminole Tribe of Florida Tribal Wildlife Program

Penobscot Indian Nation ($199,980)
Atlantic Salmon Enhancement on Trust Lands

Leech Lake Band of Ojibwe ($196,240)
Influence of Forest Structure and Composition on the Space Use Survival and Interactions of Snowshoe Hare and Fisher

NEW YORK:            
Seneca Nation of Indians ($199,483)
Seneca Nation Conservation Management Action 2015

NORTH CAROLINA:             
Eastern Band of Cherokee Indians ($200,000)
Eastern Band of Cherokee Indians Tribal Wildlife Action Plan


The Klamath Tribes ($200,000)

The Re-introducing Extinct Populations of Endangered Suckers in the Upper Klamath Basin grant will assess and restore spawning habitat for endangered Lost River and shortnose suckers in Upper Klamath Lake Oregon. The overall goal of the Klamath Tribes effort is to save the sucker species from their continued decline and potential extirpation from the wild, as well as ultimately achieve recovery.

Confederated Tribes of the Warm Springs Reservation of Oregon ($200,000)
Coyote Creek Sub-watershed Restoration and Protection Project

Lower Brule Sioux Tribe ($200,000)
Assessment of Resource Selection and Survival of a Declining Pronghorn Population

Puyallup Tribe of Indians ($199,879)
South Rainier Elk Herd Habitat Enhancement and Population Monitoring

Suquamish Tribe ($200,000)
Sea Cucumber Restoration Pilot Project

Tulalip Tribes of Washington ($199,906)
Using Beaver to Restore Ecosystem Functions in the Snohomish Watershed

Red Cliff Band of Lake Superior Chippewa ($199,761)
American Marten Study: Population Dynamics and Habitat Use on Red Cliff Reservation




For additional information about Native American conservation projects and the Tribal Wildlife Grants application process, visit

Mar 272015

The greater sage-grouse cannot stay out of the news long. On Thursday, the Interior Department announced an agreement with Barrick Gold of North America and The Nature Conservancy allowing Barrick "to accumulate credits for successful mitigation projects that protect and enhance greater sage-grouse habitat on the company’s private Nevada ranch lands."

The company owns a lot of ranch lands in Nevada. Interior said a Nature Conservancy forecasting tool "will be applied to 582,000 acres of ranch lands under Barrick management in Nevada."

Because I am a lazy reporter and it is rather late at night, I'll simply paste the rest of the department's news release below, indented to make it clear this is DOI's writing, not mine, which would no doubt be riddled with typos.

But because the greater sage-grouse is a bird that seeks the limelight, there's more: Interior Secretary Sally Jewell will be announcing another sage-grouse agreement Friday in Bend, Ore., with a cast of luminaries including Oregon Gov. Kate Brown, USDA Deputy Under Secretary for Natural Resources and Environment Ann Mills, FWS Regional Director Robyn Thorson, and BLM Deputy Director Steven Ellis. John O'Keefe, President-Elect, Oregon Cattlemen's Association, rounds out the crew. So, if you're at the Deschutes National Forest Office at            63095 Deschutes Market Rd in Bend ab0ut 1:45 p.m. (that's PT, of course), give me a call so I can listen in, or take a few photos (excuse me, digital images). I promise I'll post them here.

And, let's not forget the announcement last week in Wyoming of "the nation’s first conservation bank for greater sage-grouse."

On Tuesday, March 18, "at a ceremony in [Cheyenne] hosted by Governor Matt Mead, Interior Deputy Assistant Secretary Jim Lyons, Fish and Wildlife Service Deputy Director Jim Kurth and Jeff Meyer, Managing Partner of the Sweetwater River Conservancy, formalized the agreement creating the project, which ranks as the largest conservation bank in the country," FWS said.

Don't know how I missed that one. Blink and you'll miss the latest announcement about land being managed/conserved/spruced up for the sage-grouse, all of which leads one to believe that an announcement in September that the bird has managed to avoid ESA listing is, how shall we say, in the bag?

Anyway, if you haven't already left this page long ago, here's that Barrick release:

The agreement among the U.S. Fish and Wildlife Service, Bureau of Land Management and Barrick establishes a conservation bank that allows the mining company to accumulate credits for successful mitigation projects that protect and enhance greater sage-grouse habitat on the company’s private Nevada ranch lands. As a result, Barrick gains certainty that the credits can be used to offset impacts to habitat from the company’s planned future mine expansion on public lands.

BLM, FWS and Barrick have all agreed to use The Nature Conservancy’s science-based Sage-grouse Conservation Forecasting Tool to quantify the benefits of habitat conservation projects on the company’s ranch lands and adjacent public lands as well as the impacts of Barrick’s future proposals for mining activities in the area. This unprecedented use of a conservation bank agreement adds to a suite of tools that can provide greater certainty to public land users by compensating for any adverse impacts their actions may have on public resources while permitting important economic activities. On a broader scale, the State of Nevada’s conservation credit exchange system, developed in concert with Environmental Incentives LLC, could facilitate other similar agreements to improve habitat and provide certainty to industry.

“This is the kind of creative, voluntary partnership that we need to help conserve the greater sage-grouse while sustaining important economic activities on western rangelands,” said Secretary of the Interior Sally Jewell. “This conservation banking agreement and Barrick’s partnership with The Nature Conservancy illustrates the kind of public-private collaboration that is essential to a successful effort to conserve rangeland habitat for people and over 350 species of wildlife.”

“When we first approached the Interior Department with this idea, we wanted to demonstrate that industry, regulators and conservation experts can work together to solve complex problems,” said Michael Brown, Executive Director of Barrick North America. “After many years of working with The Nature Conservancy, we are excited to see what they can do to help us improve habitat on our ranch lands and, hopefully, to provide a model for others interested in making similar improvements. We’re pulling many years of experience and cutting-edge conservation science together to protect the sage grouse, which, in turn, supports the broader ecosystem.”

The conservation bank concept commits Barrick and other land users to achieve ‘net conservation benefits’ for the greater sage-grouse by encouraging greater gains in functional sage grouse habitat through preservation and restoration than what is lost through development activities. Over time, the application of this concept should result in significant, landscape-scale improvements to habitat conditions throughout the region. Through implementation of this conservation bank, Barrick will obtain assurance that the voluntary compensatory mitigation measures taken by the company, when sufficient to provide a net conservation gain to the species, will be accounted for by BLM and the FWS as the agencies review the company’s future proposed mining operations.

The Nature Conservancy’s Sagebrush Conservation Forecasting Tool uses satellite imagery to create maps of current habitat conditions. Scientists then employ predictive computer models that simulate the natural patterns of vegetation change over time (e.g., young to mature plants), to identify which restoration actions will be most helpful to sage-grouse.

“By engaging with Barrick and the Department of the Interior, we can use our scientific and conservation planning expertise to help inform decisions that protect, manage and restore vital wildlife habitat on potentially hundreds of thousands of acres of land,” says Michael Cameron, Associate Director of the Nevada Chapter of The Nature Conservancy. “Working together we can have a meaningful impact that supports both conservation and the economy of Nevada.”

In addition to its gold mining operations, Barrick owns several Nevada ranches. The company has completed a variety of habitat improvement projects on these ranches over the past 25 years, supporting mule deer, native fish and other species. The Nature Conservancy’s forecasting tool will be applied to 582,000 acres of ranch lands under Barrick management in Nevada. The agreement sets the stage for more investment in conservation of greater sage-grouse habitat, but it does not change or exempt Barrick from any existing laws and regulations governing its mining activities and its responsibility for environmental protection.

Other public land users are also stepping up to improve conservation practices. Ranchers in Oregon and Wyoming, for example, have committed to implement measures that will protect greater sage-grouse habitat across millions of acres of rangelands in return for assurances that, should the bird be listed as endangered or threatened, their operations will not be affected.

Secretary Jewell added, “Through landscape level mitigation efforts, conservation banks, credit exchanges, conservation easements, and conservation assistance programs, we are advancing partnership efforts that are redefining how we achieve our conservation goals across the American West.”

Through this sage-grouse effort and others, the Department is implementing the Secretary’s vision for more meaningful, landscape-level investments to compensate for development impacts.

Greater sage-grouse once occupied more than 290 million acres of sagebrush in the West, but the bird, known for its flamboyant mating ritual at sites called leks, has lost more than half of its habitat due to growing threats from conversion to agriculture, rangeland fire, invasive species and development.

The deteriorating health of western sagebrush landscapes has sparked unprecedented and proactive collaboration across 11 states. These collaborations are conserving uniquely American habitat that supports wildlife, outdoor recreation, ranching and other traditional land uses.

More information on the greater sage-grouse and the ongoing, collaborative work to conserve the sagebrush landscape is available at:

Mar 262015

The Ninth Circuit has dismissed as moot a challenge to the operations of Sharp Park golf course in the city of San Francisco (Wild Equity Institute v. City and County of San Francisco, 13-15046).

"Wild Equity argued on appeal that the [Incidental Take Statement] had no independent force prior to its incorporation into the City’s CWA permit. However, the Corps has since issued the relevant permit, which incorporates the terms of the ITS," the court said in a memorandum opinion issued yesterday (March 25, 2015).

Wild Equity argued "that the capable of repetition yet evading review exception to mootness applies," but the court said that "[t]he issuance of the ITS and CWA permit have . . . fundamentally changed the legal landscape within which the parties are operating, reducing the likelihood that this issue will arise again between these particular parties."

Coverage from Nossaman LLP

Previous appeals court decision

Mar 262015

NMFS has "accepted" two porbeagle shark listing petitions for full review, in light of (in the wake of, following, in compliance with -- pick a phrase, any phrase) a federal judge's order in December (though the opinion preceded it).

NMFS porbeagle shark page :: WildEarth Guardians petition :: HSUS petition

Mar 242015

We had a brief story on this yesterday, with a link to the court's decision. Yes, I am forcing you to go to that page.

Press Release from the Southern Environmental Law Center and Black Warrior Riverkeeper

For Release: March 24, 2015


Catherine Wannamaker, Senior Attorney, Southern Environmental Law Center, (650) 793-3372
Nelson Brooke, Riverkeeper, Black Warrior Riverkeeper, (205) 458-0095
Jim Hecker, Environmental Enforcement Project Director, Public Justice, (202) 797-8600 ext. 225
Mike Senatore, Vice President, Defenders of Wildlife, (202) 772-3221

Federal Court Requires Corps to Rectify Error on Water Impacts of Coal Mining Permit along Alabama’s Black Warrior River

Birmingham, AL – The U.S. Court of Appeals for the Eleventh Circuit has ruled that the U.S. Army Corps of Engineers (Corps) must rectify an error the agency made in assessing the impacts on water resources from coal mining activities under a controversial permit that authorizes unlimited mining material to be dumped into streams and wetlands in the Black Warrior River basin.

Beginning in May 2012, the Corps granted permits for limitless filling of streams and wetlands at 41 mines in the Black Warrior basin through a general approval, known as Nationwide Permit 21, rather than requiring individual review of each site as is now standard for surface coal mining activities.

The groups charge that the Corps has not fully accounted for cumulative environmental impacts allowed by the use of this permit. Over two years after the permit was issued, and a few days before oral argument in the court of appeals, the agency admitted that it had made an error in calculating the impacts of mining activities authorized by the permit, which severely undermined the agency’s finding that activities under this permit had minimal cumulative impacts.

The Court has allowed the Corps an additional year to study and calculate the actual impacts to water resources allowed by Nationwide Permit 21– a period of time during which unlimited stream filling can continue under previous authorizations unless the district court orders activities to be stopped.  Because the Court focused solely on this late-breaking error, it did not address the groups’ main argument, which is that it is irrational for the Corps to allow these mines to fill unlimited lengths of streams, despite its 2012 finding that a 300-foot limit on stream filling is “necessary” to prevent more than minimal cumulative environmental impacts.

“We are disappointed that the Court allowed the Corps an entire year to analyze environmental impacts that should have been considered more than five years ago, before this permit was issued,” said Catherine Wannamaker from the Southern Environmental Law Center. “Giving the Corps more time to justify a permit that should have never been used in the first place does not serve the public interest.  We feel strongly that all 41 permits should have been put on hold during the Corps’ reevaluation, and we are considering next steps at this time.”

One judge on the panel disagreed with the majority and argued for vacating all 41 permits, explaining that “[t]he scope of the mistake is much broader” than a simple math error, and that “the issuance of a nationwide permit . . . based on a faulty and unsupported minimal impacts analysis”  is a clear violation of the Clean Water Act

“These 41 grandfathered permits should never have been granted, because they rely on the Corps’ unsupportable and undocumented assumption that burying and disturbing tens of miles of streams has only minimal cumulative effects,” said Jim Hecker, Environmental Enforcement Director at Public Justice.

After suspending the use of Nationwide Permit 21 in 2010 for mining in other Appalachian states due to concerns of its impacts on water quality, the Corps strengthened the permit conditions on environmental impacts when reissuing it in 2012. However, the Corps included an arbitrary “grandfather” provision authorized by the previous version of the permit that allows the unlimited fill of streams and wetlands to continue under previous authorizations until 2017.

After estimating the provision would be used rarely, the Corps has approved around 80 total projects across the country through this loophole, over half of which are in the Black Warrior basin, a major source of drinking water for Birmingham, Tuscaloosa, and other Alabama communities.

The court found that the conservation groups were justified in taking time to fully investigate and prepare their claims, contrary to arguments made by the intervening coal companies that the duration of the groups’ investigation caused them monetary harm.

“This permit allows far too much damage to wetlands and streams along the river and its tributaries,” said Nelson Brooke, Black Warrior Riverkeeper.  “The Black Warrior is home to many rare and important aquatic species and is used heavily for swimming, recreation, fishing, paddling, and boating. Protection of clean water and its upland sources are vital to downstream uses.”

When the permit was reissued in May 2012, over 145,000 linear feet of streams (approximately 27 miles) in the Black Warrior basin were authorized for fill of mining material under Nationwide Permit 21, even though the Corps has recognized in other contexts that stream fills can compromise water quality and wildlife habitat.

“Streams and wetlands play an integral role in protecting the overall health of the river by filtering out pollution and sediment,” said Michael Senatore, from Defenders of Wildlife. “Continuing to dump massive amounts of rock, soil and chemical waste into these delicate water bodies could ultimately cover and permanently destroy them, resulting in catastrophic habitat loss for fish and wildlife and serious impacts for downstream communities that rely on the Black Warrior watershed for their drinking water.”

Black Warrior Riverkeeper, Defenders of Wildlife, the Southern Environmental Law Center and Public Justice filed a lawsuit in November 2013, charging that the Corps’ issuance of Nationwide Permit 21 fails to comply with federal requirements for surface mining without the detailed study and analysis of cumulative impacts required by the Clean Water Act and the National Environmental Policy Act.  The case is Black Warrior Riverkeeper v. U.S. Army Corps of Engineers, No. 14-12357 (11th Cir.).

In two prior lawsuits brought by Public Justice against the Corps in Kentucky and West Virginia, federal courts have already declared Nationwide Permit 21 to be in violation of these laws.


About the Southern Environmental Law Center:

The Southern Environmental Law Center is a regional nonprofit using the power of the law to protect the health and environment of the Southeast (Virginia, Tennessee, North and South Carolina, Georgia, and Alabama). Founded in 1986, SELC's team of nearly 60 legal and policy experts represent more than 100 partner groups on issues of climate change and energy, air and water quality, forests, the coast and wetlands, transportation, and land use.

About Black Warrior Riverkeeper:

Black Warrior Riverkeeper’s mission is to protect and restore the Black Warrior River and its tributaries. The citizen-based nonprofit organization holds polluters accountable because all deserve clean water for drinking, swimming, recreation, fishing, and wildlife habitat throughout the Black Warrior River watershed. Learn more at

About Defenders of Wildlife:

Defenders of Wildlife is dedicated to the protection of all native animals and plants in their natural communities. With more than 1 million members and activists, Defenders of Wildlife is a leading advocate for innovative solutions to safeguard our wildlife heritage for generations to come. For more information, visit

About Public Justice:

Public Justice is a national public interest law firm dedicated to using creative litigation to advance the public good, protect consumers, employees, civil rights and the environment. For more information, visit