Endangered and Threatened Wildlife and Plants; 90-Day Findings; Diamondback terrapin

The Center for Biological Diversity, along with Project Terrapin, submit the following comments in support of USFWS' positive 90-day finding that diamondback terrapins may warrant protection under the Endangered Species Act. We are strongly in favor of listing. Our comment letter (see attached file) details our ongoing work to encourage state-level bycatch reduction device (BRD) regulations and voluntary BRD use; we also summarize newer studies and expert opinions obtained since the original petition submission in 2024. It is clear that states are unable or unwilling to protect these beautiful turtles from the host of threats which they currently face, specifically the threats of poaching and drowning in crab pots but also extending to habitat loss, nest predation, and climate change. Diamondback terrapins nearly went extinct because of human activity over a century ago, and we are lucky they are still around today. We cannot rely on luck to save them a second time.