Tips for public comment on hellbender protections ahead of Feb. 11, 2025, deadline

Recently, on Dec. 12, 2024, the US Fish and Wildlife Service changed its stance and proposed the Eastern hellbender as an endangered species. 
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Nationally, public comment is accepted until 11:59 p.m. EST on Feb. 11, 2025, before the final decision is made on protections. This is your opportunity to give this vulnerable clean water indicator species a voice.

With that in mind, here are some tips for public comment, as well as Middle Susquehanna Riverkeeper John Zaktansky's letter for reference and some other resources.

Per the site, a comment can express simple support or dissent for a regulatory action. However, a constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making.

These tips are meant to help the public submit comments that have an impact and help agency policy makers improve federal regulations:

• Read and understand the regulatory document you are commenting on
• Feel free to reach out to the agency with questions
• Be concise but support your claims
• Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
• Address trade-offs and opposing views in your comment
• There is no minimum or maximum length for an effective comment
• The comment process is not a vote – one well supported comment is often more influential than a thousand form letters

With all that being said, it is important to have background on the species. Our running hellbender page is a compilation of different hellbender stories during the past several years of coverage. 

If you want something more compact, we'd recommend looking over our hellbender e-magazine that includes information from local experts on why they feel the species deserves protections, important timelines from our area related to the species and more:

Hellbender cover

Once you feel you are ready, can submit your comment by clicking here. If you'd like, Middle Susquehanna Riverkeeper John Zaktansky is willing to look over your letter/comments before you submit them or can help submit them for you. If you'd like assistance, reach out to him via email or fill in the following form. Below is an example of public comments he is submitting.

​The public comment from Middle Susquehanna Riverkeeper John Zaktansky:

Only in Pennsylvania, where the Eastern hellbender is the official state amphibian, can you drive a car with an Eastern hellbender on your license plate to a hellbender 5K, race against competitors along a waterway that once was home to hellbenders, and then celebrate your victory by knocking back a few Hellbender-named lagers or pale ales at the local pub. 

All of this without really ever directly making a real difference for a species that has lost upwards of 95 percent of its habitat across the Susquehanna River basin.

The awareness we have for the hellbender in central, northcentral and northeast PA for the hellbender is incredibly admirable, and people truly want to make a difference. Events and specialized products featuring the species typically do donate generally toward habitat improvement, but hellbenders need a specific type of aquatic habitat and an organized approach to connecting these hubs of prime habitat.

The giant salamander – the largest in our country – requires large rock structures on the bottoms of streams for shelter. Sedimentation is a major threat, especially in waterways that are impacted in our watershed by industry that draws water from our streams and river. 

The hellbender also “breathes” directly through its skin, including the numerous lasagna-like wrinkles on its side that increase surface area. So, if a waterway becomes polluted, the hellbender is one of the first species impacted. 

This is obviously an issue in a state with thousands of miles of impaired waterways connected to abandoned mine drainage alone, not to mention concern with stormwater and agricultural runoff, an aging sewage infrastructure, microplastics, pharmaceuticals, PFAS and a cocktail of other contaminants. 

Despite all this, there are still some pockets of pristine hellbender habitat in our watershed where the species can be found. I was helping with some research this past summer in one of these locations, where more than a dozen healthy hellbenders were located, studied, measured and safely put back exactly where they were discovered. 

I remember feeling a bit anxious for these hellbenders as I left. While they were managing well in this small portion of watershed, they are completely vulnerable to anything that happens upstream of them. A big storm event, a toxic chemical spill, a construction site where erosion protocol isn’t followed – and so many other scenarios that realistically could instantly wipe out this isolated population. 

Pennsylvanians were promised, back in 1971, the right to “clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment” via the Environmental Rights Amendment. And yet, in the 50 years of waterway regulations, cleanups and other best management practices since, the hellbender population continues to drastically spiral downward. 

We had our chance to fix the problem, and we obviously need outside assistance via federal protections before it is too late. We still don't know enough about hellbender nesting behavior and potential cannibalism issues related to that – an issue found in more recent studies and something we've been looking into directly with local partners. We don't know about impacts of various contaminants working together in the hellbender's system. We don't have enough data on the long-term success of habitat augmentation efforts and how well juvenile hellbenders released by researchers will factor into the natural breeding pool. 
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It is obvious the Eastern hellbender needs federal endangered status until we can better understand these unknowns before we completely lose the final few populations we have within our watershed.