In addition to the comments submitted to the U.S. Fish & Wildlife Service by WVFA concerning the potential listing the Northern Long-Eared Bat as Threatened, under the Endangered Species Act (ESA), WVFA also joined other forestry community members as a signatory on another comment-letter by the due date of March 17.

The first section of that letter was focused on legal concerns. The substantive issues are raised in the latter part and include:

1. The bat does not warrant listing; but if the bat is listed, it is because of the White-Nose Syndrome disease – PERIOD.
2. If listing warranted, it should be as "Threatened" to allow the most management flexibility.
3. The 4(d) rule of the ESA needs to be simplified to clearly exempt all forest management activity from what is termed a "take" in the ESA.
4. A reminder that active forest management can and does promote bat habitat.