State Game Commission's bat protection rule would create economic burdens for job creators
PA Chamber members express concerns in letter to agency

September 18, 2012

The PA Chamber recently submitted to the Pennsylvania Game Commission its members’ official comments regarding a proposed rulemaking that offers protections for certain bat species in Pennsylvania. The rule’s potential economic impact tops the PA Chamber’s concerns.

The PGC’s intention is to label as endangered the Northern Long-Eared Bat, the Tri-Colored Bat and the Little Brown Bat in an effort to prevent the spread of white nose syndrome among those bat populations.

In its comment letter to the agency, the PA Chamber expressed concern that the rulemaking is being issued without consideration to the negative economic impact it could have on the regulated community, especially industries that operate in areas where the bats reside.

The PA Chamber also questions whether the state Game Commission has the legal authority to enforce the policy, since it is not formally issuing a regulatory change. In addition, PA Chamber members noted that the agency’s data shows that bat populations have remained steady and even stabilized in recent years, which would render the new proposal unnecessary.  

In light of a current review of the bats’ endangered status by the U.S. Fish and Wildlife Services, a determination that the species is threatened would require permit applicants to follow rules set forth by the USFWS and the PGC – a duplicative and confusing ordeal.

In summary, PA Chamber members are asking that no further action be taken on the rulemaking until the Game Commission establishes a stakeholder process in order to work with the business community to address these concerns and develop a series of agreed-upon, workable solutions.



Founded in 1916, the Pennsylvania Chamber of Business and Industry is the state's largest broad-based business association, with its membership comprising businesses of all sizes and across all industry sectors. The PA Chamber is The Statewide Voice of Business.