The Endangered Species Act (ESA) should act as a framework for recovery, not a permanent designation. Unfortunately, species often remain on the list for decades, without proper analysis or in contrast to the best available science. For instance, Ute ladies’-tresses have been listed under the ESA for decades, despite scientific evidence demonstrating they exist throughout the West in large, thriving populations. This has adversely affected water and grazing projects throughout the State. PLPCO promoted and actively guided state and federal collaboration to review existing data and begin a species status assessment (SSA), utilizing the best available science. That effort resulted in the following:
- New research proving the species is far more resilient than previously thought, with populations spanning eight states.
- In January 2025, the U.S. Fish and Wildlife Service formally proposed delisting the species, removing federal hurdles for Utah’s riparian and development corridors.
Utah’s “management-first” approach ensures that once species recover, they are delisted to restore local management and ensure that species remain protected through collaborative wildlife management. Additionally, to avoid the economic restrictions of new listings, PLPCO is co-leading the development of Conservation Agreements and Strategies (CA&S). These documents serve as stakeholder commitments to improve habitat health, protect sensitive species, and close critical data gaps to demonstrate for the FWS that listing under the ESA is unnecessary.
- Pinyon Jay: Utah is at the core of the pinyon jay range. PLPCO and the Division of Wildlife Resources (DWR) are working with other state and federal agencies to draft a CA&S focused on habitat health and the maintenance of state management authority over the species.
- Wilson’s Phalarope: This migratory species of the Great Salt Lake has been petitioned for listing under the ESA. PLPCO is working with state and federal agencies to develop a multi-state conservation agreement. Additionally, because Wilson’s Phalarope migrates from the Great Basin to South America, PLPCO is working with international partners to collect the best available science and provide FWS with the information necessary to properly evaluate the listing petition.

