Document Type


Publication Date


Publication Citation

26 Stanford Environmental Law Journal 77 (2007)


On June 26, 2006, the U.S. Fish and Wildlife Service (FWS) issued three new final policies governing the conservation of the national wildlife refuge system. These new agency manual provisions nearly complete an implementation project that began shortly after Congress enacted an organic statute in 1997 for management of the refuges. This article briefly reviews the significance of the 1997 legislation and places the new policies in the context of the statutory framework. It then discusses the most important aspects of the policies in terms of both practical refuge management and broader trends in natural resources law. The article evaluates the legal status of the policies with a special focus on whether the judiciary would bind the FWS to follow them. The article concludes with suggestions for the next round of FWS policymaking for refuge conservation.