@Nonilex
(1/2) My comment:
I urge you to reject the proposed rule change.
Clearly "the definition of “harm,” like the other nine verbs in the definition, should be construed to require an “affirmative act[ ] . . . directed immediately and intentionally against a particular animal—not [an] act[ ] or omission[ ] that indirectly and accidentally cause[s] injury to a population of animals.” " is a misleading statment that fails to recognize the ability to predict cause and effect - something scientists, and wildlife biologists, have made great progress in doing with increasing accuracy.
It is clear that ANY act that changes the environment in a way that can reasonably be expected to reduce the "population" of specified animals causes harm. The fact that such act is committed by entities that know, or should have known, that it "causes injury" of protected species is clear indication of intent.
(Continued)