Department of Fisheries, Wildlife, and Conservation Science
Oregon State University
February 1, 2025
What is the proper role of government employees when their personal policy preferences differ from those of their employer? Specifically, is it acceptable for government employees to play a role in sweetheart or sue and settle lawsuits? To begin formulating an answer, here is a case study (based on a real event, but written to conceal specific individuals or lawsuits:
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The Case Study
(Based on DC experience. Most specific references are altered.)
Ever since a Grade 4 field trip to a nature reserve, Rena Webfoot was fascinated by amphibians. Eventually, she finished a Master’s degree in conservation biology. Her thesis research topic, not surprisingly, focused on determining the cause of the worldwide decline of amphibians and, specifically, the Scarlet Toad.
Starting in graduate school, she was active in the Society for Conservation Biology, the International Union for the Conservation of Nature, and the Sierra Club. After completing her Master of Science degree, she held several jobs in environmental and natural resource agencies. Still, it was not until she landed her dream job as chief of the Amphibian Branch within the Office of Threatened and Endangered Species within the US Fish and Wildlife Service, part of the Interior Department. There were hundreds of species under consideration for listing under terms of the Endangered Species Act. The Office Director regularly made decisions about assigning staff to evaluate specific species. With the resources available, many species dropped down the priority list for evaluation, while others were fast-tracked.
One day, as Ms. Webfoot reviewed the updated candidate species list, one species jumped out. Halfway down the list was the Scarlet Toad, the same species she had studied for her Master’s degree. She felt passionate about this species ― after all, she had spent many long nights observing them in the wild. That same day, she met with the office director to make her case that the species should be listed immediately. The office director listened, but he concluded their meeting with an unwelcome (to her) decision:
"We have many species we could, arguably, evaluate with the available resources. In terms of risk, the Scarlet Toad is of average risk and not in the top tier. I focus our resources (workforce) on the species at greatest risk of near–term extinction. The Scarlet Toad does not, in my opinion, meet these criteria. The line must be drawn somewhere."
Never one to accept defeat, Ms. Webfoot talked to her amphibian colleagues about the Scarlet Toad at the next local DC chapter meeting of The Society for Conservation Biology. Several suggested she contact her former fellow graduate student now at the Center for Biological Diversity. That very day, she did. He (an outreach staffer) listened to her carefully, then concluded that this was a case that they (CBD) could probably win — or at least force the Fish and Wildlife Service to move the Scarlet Toad into the “critical” category, thus eligible for immediate evaluation and likely listing. He requested that she discretely send him the relevant inside scientific and assessment file on the species. He would share this information with their lawyers and let her know (orally) of their decision. In any case, she was advised not to put anything in writing, nor talk to Office colleagues unless she was convinced of their discretion.
Nothing happened for a few months. Eventually, the Department of Interior’s Office of General Counsel contacted the Endangered Species Office Director (her boss) and notified him that the Government had been sued by the Center for Biological Diversity for failure to list the Scarlet Toad. To the Department’s lawyers, it looked like the plaintiff’s case was strong. Based on considerable experience with similar lawsuits, they estimated that this case would take years to play out. The Office of General Counsel had a limited number of lawyers, the Scarlet Toad listing was not a high priority politically, and he was reluctant to burn many “billable hours” defending the Department in a low-priority lawsuit.
The main argument of the lawsuit would be that the Fish and Wildlife Service had “arbitrarily and captiously” moved the Scarlet Toad down the candidate list. Thus, it would be years until it rose to the first tier. In essence, the Government lawyers would negotiate with the Center for Biological Diversity to avoid costly litigation. In the settlement, the Department would agree to move the Scarlet Toad to the top of the candidate list if the Center would withdraw the lawsuit. This tradeoff was the usual way that these cases were handled. Besides, the Government would agree to pay their legal fees ($48,000). This strategy would be less expensive to the taxpayers than defending the lawsuit. From the lawyer’s perspective, this was all pretty routine.
The Office director called Ms. Webfoot into his Office and directed her to move the Scarlet Toad to the top of her priority list and have her staff start working on the listing. Ms. Webfoot was ecstatic. Her supervisor was visibly less pleased and wondered aloud how the Center was tipped off and acquired copies of their key in-house documents. With a wink, he wished her well. They both went back to work.
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The Rena Webfoot case study is a heavily edited description of a hypothetical example of a sweetheart lawsuit based on my experiences with the Fish and Wildlife Service (Department of the Interior) and the U.S. Environmental Protection Agency in Washington, DC. The specifics are well-modified to avoid speculation about who was involved.
There are no universally accepted definitions of sweetheart or sue and settle lawsuits, nor is their frequency in ecological policy disputes known with confidence. Typically, a sue and settle reference involves collaboration between government bureaucrats working in their official capacity with one or more environmental or ecological advocacy groups.
Related to sue and settle lawsuits, but with differences, sweetheart lawsuits tend to be applied as a descriptor to cases when individual government employees work outside (and often secretly) their official duties to facilitate a lawsuit against the agency.
Usually, such lawsuits are encouraged by the Government employee operating as a member of, or supportive of, a professional or advocacy organization. For example, a government scientist working for the U.S. Forest Service, might be a member of the Sierra Club and help that organization sue the Federal Government to force the adoption of a policy (e.g., eliminating commercial logging) that the employee (and the Sierra Club) prefer.
While the total number of lawsuits targeting the Federal Government is relatively easy to determine, it is difficult to separate how many involve unofficial collaboration between Federal employees and advocacy organizations. Specifically, how often Federal employees use information and insights gained through their government jobs is unknown.
Based on my experience, it seems relatively common with governmental regulatory organizations (i.e., Environmental Protection Agency, U.S. Forest Service, and Bureau of Land Management) and professional/scientific organizations (i.e., American Fisheries Society, The Wildlife Society, Society for Conservation Biology, and Society of American Foresters).
Behind the anonymity of government bureaucracy, these kinds of “real world” situations are common. You should expect to encounter such examples in your career. Presumably, in your analysis, you would point them out to the public and policy makers ― or would you? Whether this tactic is appropriate — or not — is entirely a judgment that would vary among the various players in policy debates. Some would regard a “sweetheart lawsuit” as an underhanded and unfair advocacy tactic. Conversely, others would argue that organizations that employ such tactics merely do what the laws allow. Analysts do not pass judgment, much less decide such questions.
So, your challenge with this case study is to assess whether such behavior by a Federal (or other government) employee is appropriate and ethical. Some might argue that an employee (paid by the taxpayers) should be policy impartial in all job–related dealings and not use their inside information to favor a particular policy preference. Conversely, others might argue that strongly held personal values from a scientific expert outweigh an obligation such employees have to be policy impartial. There are likely other positions that employees assigned to work on endangered species issues might hold.
Depending on an advocate’s policy preferences, sweetheart lawsuits are typically viewed from one of several perspectives:
(a) An effective advocacy weapon that is available to anyone — and it is often highly effective.
(b) An example of an unintended and undesirable consequence of the ESA which creates a situation where “insiders” (Government employees and ENGOs (Environmental Non-Governmental Organizations) collude to implement their policy objectives (not those of the public).
(c) An avenue for Government employees to operate as private citizens to push their personal policy preferences outside the constraints of their official duties and thus compromise their employer’s mission.
As a policy analyst, regardless of your personal opinion or policy preference, sweetheart lawsuits are common, often involve Government employees engaged outside their official duties, and are highly effective in achieving the suing organization’s policy goals. Analysts and policy makers should be vigilant in watching for them. Considering sweetheart and friendly lawsuits as a policy analyst, think about these broader policy questions:
- What do you think about such lawsuits that depend, at least in part, on information supplied (usually secretly) by Federal employees outside their official duties? Should Rena be disciplined or lauded? Are there (or should there be) Codes of Conduct for government employees about participating in such activities that are outside their job descriptions or assignments?
- How has the topic of sweetheart and friendly lawsuits been covered in your past natural resource and environmental management classes (i.e., was it presented as a good thing or a bad thing)? Do you think most people assume that government employees play it straight (i.e., act impartially)?
- Thinking more broadly about ecological policy and beyond the narrow specifics of the Scarlet Toad case study, would most people (i.e., voters) consider Rena’s behavior as commonplace for government workers? Conversely, perhaps they regard such behavior as a violation of public trust (i.e., taxpayer-funded employees should remain impartial and free of personal policy preferences in executing the laws of the land) and, therefore, Rena’s behavior is unacceptable.
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Author Info:
Robert T. Lackey <Robert.Lackey@oregonstate.edu> is a professor of fisheries at Oregon State University, where he teaches a graduate course in ecological policy and mentors graduate students. He was previously deputy director of the U.S. Environmental Protection Agency’s 350-person National Environmental Research Laboratory in Corvallis, Oregon, from which he retired in 2008. He has also worked on assignments in Washington, DC for the U.S. Department of Interior and the U.S. Environmental Protection Agency.
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This is an excellent practical example of a real-world problem that natural resource professionals run into once that reach mid-career levels. I hope the students all came up with the obvious answer, “Such behavior as a Federal employee is not only unethical, it is likely a firable offense.” Using a Civil Service position for such advocacy is one reason why many voters don’t trust us to be impartial. I wish I would have been confronted with such topics and discussions when I was a graduate student many years ago. More recently, I have seen my professional society (and some colleagues) go down this path.
Well, gov’t leaks in general are in the public interest for transparency (Hughes et al. 2023), esp. now that the news media doesn’t do a good job anymore (IMO). Unfortunately, agency leaders often cover up mistakes (op. cit.; Hughes et al. 2021, 2024), rather than use ‘em as a learning experiences to apply adaptive mgmt. (Vadas and Hughes 2024). But such sci. advocacy must be done carefully & w/ good judgment to avoid backlashes (Hughes et al. 2021).
-Bob V.
References
Hughes, R.M., and seven coauthors. 2021. Why advocate – and how? Pages 177-197 in D. DellaSala (ed.). Conservation Science and Advocacy for a Planet in Crisis: Speaking Truth to Power. Elsevier. Cambridge, MA (cf. https://www.sciencedirect.com/science/article/pii/B9780128129883000156).
Hughes, R.M., and 10 coauthors. 2023. Global concerns related to water biology and security: the need for language and policies that safeguard living resources versus those that dilute scientific knowledge. Water Biology and Security [online] 2(4): 100191 (https://www.sciencedirect.com/science/article/pii/S2772735123000719).
Hughes, R.M., and seven coauthors. 2024. Environmental impact assessments should include rigorous scientific peer review. Water Biology and Security [online] 3(3): 100269 (https://www.sciencedirect.com/science/article/pii/S2772735124000301).
Vadas, R.L. Jr., and R.M. Hughes, eds. 2024. Monitoring and Conservation of Freshwater and Marine Fishes: Synopsis and Special Issue. Fishes [online] 9(12): 470 (https://www.mdpi.com/journal/fishes/special_issues/1N7J6D5S01).
And to respond to PhyS, 1 has to use good ethical judgement to decide whether to leak info, & to be careful of envir. NGOs that often have their own axes to grind (Hughes et al. 2021). Although I was at 1st put off by what Edward Snowden did, the movie about him showed how he tried to work w/in gov’t before doing the leak to show how Americans & others were being spied on. I don’t believe in being a mindless puppet to bad, dishonest leadership. And now w/ AI, we’ve got spying, gentrification, & eco-damage w/o public consent as runaway problems that may require further civil disobedience vs. “The Man”:
Squirrel, T. 2024. Unplug the machine: resisting the tech hellscape. Slingshot (Berkeley, CA) 141: 8-9 (https://slingshotcollective.org/8-unplug-the-machine-resisting-the-tech-hells-cape).
In sum, ethics is a double-edged sword that requires wisdom to navigate.
Bob raises more interesting points. Having been long in a government resource agency this story is not really anything new. I suspect my ideas will reflect a naive view, but here goes. A government resource agency is responsible for discovering and understanding the science around the resources they manage. They are the depository of the accurate data and information. As an entity supported by public funds, all that information is available to the public, free of charge as they have already paid for it. Technical staffs’ responsibility, when presenting information as an employee, in the dissemination of information is to provide it free of personal bias. At the same time, it is the responsibility of the policy staff to publicly provide the policy that guides use of the science. The agency should support public discussion of the science and policy reasons for actions. Lack of budget, triage, and so on are all viable reasons for action/inaction. This is likely a fantasy view. In the real world, especially where agencies muzzle staff, is that one needs to (carefully) work on their own time and dime using data available to the public. Might also help to creatively suggest questions for outsiders to ask pointed questions. I still believe my agency job is an advocate for the resource; it is up to others to advocate for harvest, protection, destruction, etc.
Yes Hal, we scientists are also citizens, & those of us w/ a conscience should be whistleblowers or leakers when needed. But work thru professional channels 1st, as creative solutions can often be achieved thru negotiation. But until the world is rid of dishonesty (which likely won’t be ’til human extinction), then we have to stand up for something, rather than fall for anything (like the C&W song goes). And don’t just advocate for something b/c it’s one’s “pet” issue; there’s gotta be sci. to back it up.
Notably, favoritism is what both major political parties do now. And even in the past, the reason that Kyoto didn’t get nuked was b/c an American leader had liked that city, which had good karma.
There is another aspect of the Sue and Settle lawsuits, At least some entities have made a profitable industry out of it because of agency incompetence. Agencies leave so much low-hanging fruit around that somebody has to pick it.
Yah Hal, opportunism abounds via loopholes. Here are 2 relevant quotes from the ‘Bad Religion’ album “Age of Unreason” re: sci. denial, etc.:
“They think that they can alter and sway which version of freedom reigns. If everything is subjective, then what good is truth anyway?” (in the rock song “Old Regime”).
“No one ’round here can contain their fears, just contented with false hope to soothe the tears. Faith is king while truth is on the lam, disenfranchised scientists be damned.” (in the rock song “Downfall”).
So we gotta know when to disseminate the truth, when others won’t, but it takes patience & wisdom to know when to go for the BATNA.
The conspiracy theorist in me might wonder if agencies might, at6 the proper time, encourage somebody to leak information so that a lawsuit will force the agency to do what wants to do but has not the political will to do so. Back in the late 1800s there was a significant issue in the Central Valley of CA with debris from hydraulic mining destroying agricultural lands. Time after time the Feds told the state not was a state issue but the state had not the will to act. Finally, a Federal judge did. Which allowed the State to get what it needed but blame the Feds.
Hal, I agree that gubmint strategy can include leaking, as well as not having state AGs argue bad cases w/ all their might. It’s good that some use their consciences in at least subtle ways!
I am pretty sure that I have been used, with my rather avid support, to do some end-arounds. At least sometimes agency leadership would like to see a more open discussion.
And here’s a classic paper that emphasizes the importance of distinguishing reliable sci. from conflicting values in aquatic mgmt.:
Policansky, D. 1998. Science and decision making for water resources. Ecological Applications. 8: 610-618 (cf. https://www.jstor.org/stable/2641253).
Such delineation should help determine whether negotiations or BATNA are best focused on.
Response to Robert Vadas and Hal Michael –
The case study posted in this blog about Rena Webfoot includes facts that you have (apparently) ignored in finding her behavior as a government employee to be acceptable (even encouraging her):
1. In the case study, Rena Webfoot worked for the Federal Government and her job was to assess the likelihood of species extinction within her prevue (i.e., amphibians).
2. She arguably had some degree of conflict of interest because she was (admittedly) partial to a particular species (Scarlet Toad).
3. Government scientists with a conflict of interest in executing their official duties must either recuse themselves, or have the potential conflict of interest assessed and adjudicated by an Ethics Officer (or something similar depending on the government agency).
4. Regardless, without declaring her conflict of interest, Rena presented her case for moving the Scarlet Toad higher on the priority list. Her supervisor (the Office Director) listened to her arguments but did not change the ESA species priority list.
5. Unhappy with the decision, she leaked her (and her staff’s) files created while on the Government payroll to an advocacy organization because she wanted her priority (getting the Scarlet Toad listed under ESA).
6. She raised no charge of malfeasance, misconduct, or corruption on the part of her supervisor or other government officials.
7. The advocacy organization used these government files to sue her agency to achieve the policy objective she wanted (i.e., list the Scarlet Toad). This sounds like a sweetheart lawsuit to me.
Now let me get this right: you consider Rena’s behavior acceptable even though she was being paid by the taxpayers? Presumably, taxpayers expect government employees to execute their duties impartially. Thus, I find it difficult to envision any governmental agency whose code of conduct would condone such misuse of an official position. I am unfamiliar with the relevant employee behavior rules for Washington State government employees, but Rena’s behavior would warrant disciplinary action in any government agency with which I am familiar.
I think that you misread Bob’s question. As I interpreted his question it was whether the action was ethical. As you note, it may have been illegal or at least against agency rules but what were the natural resource ethics.
It reminds me of the old saw “My Country Right or Wrong”. My understand of the whole quote, in context, was ” My country right or wrong. When right, to be kept right. When wrong, to be made right.” To which I subscribe.
I agree w/ you on this, Hal. Having served on jury duty b/c I promote objectivity, you gotta have all the facts before passing judgment, & I don’t agree w/ Stephen Decatur re: “My Country Right or Wrong”. That’s what led to Nazi Germany.
And I never concluded that Rena Webfoot’s behavior was laudable or not, as it depends on whether her agency ignored sci. or she was just pushing her “pet” sp. (i.e., more info is needed). I’m just saying that it’s a tool to have an envir. NGO invoke an FOIA (or here in WA, a PDR) to keep things transparent, which is in the public interest. But do it wisely. E.g., I’ve been pushing WA to state-list Pac. lamprey b/c of its declines (cf. Storch et al. 2022), but I cont. to work collaboratively to make that happen. I.e., I don’t see the need to act like Rena Webfoot b/c biologists seem to be working in good faith on this issue (e.g., getting better data before revisiting potential listing). There’s no “cookbook” solution & I disagree w/ John B. about everything being so black-&-white w/ the case study that Bob L. presented.
Storch, A.J., and 11 coauthors. 2022. A review of potential conservation and fisheries benefits of breaching four dams in the Lower Snake River (Washington, USA). Water Biology and Security [online] 1(2): 100030 (https://www.sciencedirect.com/science/article/pii/S2772735122000440).
This is an example of the common conflict between an employee’s role as a civil servant on one hand, and a public interest scientist on the other. I have faced this dilemma many times during my 35 years. I agree with John Baboni, she should have discussed with the decision maker (which she did) and accepted his conclusion. Had she felt a compelling reason to go beyond, she should have had the NGO request the scientific analysis through the FOIA – not giving it to them on the sly. When faced with similar conundrums, I would always be up front and inform the decision maker that there was a good likelihood of being sued and losing. The outcome was variable, but it was the right thing to do.
In one particularly thorny example that I worked on had a very large regional impact and legal costs in the $millions. I noted in a memo to the decision makers that the BiOp contained a false statement. They noted the memo, but went ahead anyway. The NEPA documents and the memo were attained by an NGO through the FOIA and led to the lawsuit, which the NGO eventually won after several appeals, ultimately by the 9th Circuit. I took a lot of heat from the agencies’ leadership, but believe I acted ethically as both a civil servant and a public interest scientist. The ultimate outcome was a positive for the resource and agency dishonesty was revealed.
Bob, I’m not sure how you continue to do it; posting such great questions / scenarios, but this one is “out of the park” great. I need a bit more time to consider the many nuances of the issue(s) posed, but in general I think Ms. Webfoot acted correctly and within the policies that govern Federal Government employees. I also tend to agree with Bob Vardas in terms of the Snowden case; I think that Biden should have at least given him clemency if not pardoned him given the level of corruption that he discovered and subsequently exposed, but that is undoubtedly an unpopular position. I’m re-thinking that one too, but it’s hard to accept blatant lying and cover-up on the part of government officials.
Richard, there have been several Hollywood movies now depicting fed.-whistleblowing work by U.S. reporters, before the newspapers got too corporate for that. I consider those reporters heroes. It irked me when Obama called Snowden a “hacker”, when in fact he had worked in good faith for the feds ’til they ignored his concerns. And there have been other whistleblowers like Assange & Manning who’ve suffered greatly, definitely “killing the messenger”. And now w/ AI, we can expect the Patriot Act on steroids, ugh.
I feel your newest challenge is so appropriate given all that is happening to dedicated civil servants domestically and those posted overseas. It does require to rhetorically ask if the Government can overstep its bounds? Considering that a friend of ours with USAID has now been told to return home immediately (and within 10 days), but no details of how he and his family (spouse and three children plus their household goods) are to arrange that transfer. So far, no mention financing their return, even though the Government moved them to this post. Color me totally confused and devastated on behalf of all who have made the commitment to development activities.
Yah Richard, I’m glad that I’m a state, rather than a fed., employee, meaning less political problems. Perhaps Bob L. should post this again after a few yrs. of Trump, to see if people give different answers to the froggie dilemma. Certainly, we just put out this “WOTUS woes” paper, FYI:
Sulliván, S.M.P., and nine coauthors. 2025. Waterbody connectivity: linking science and policy for improved waterbody protection. BioScience 75: 68–91 (https://academic.oup.com/bioscience/article-abstract/75/1/68/7998043).
Bob (Vadas), I will read your article today on a long flight to Costa Rica. A quick scan indicates that it is a very comprehensive statement, one that my graduate students will be required to read. As per the abstract, the comprehensive nature of the piece is the important message. More later. Perhaps we should discuss this paper and its ideas directly so a not to divert attention from Lackey’s important question and that ongoing discussion.
Good discussion, Bob–as you may recall, when at AFS I was critical of “academics” who would research “until the last fish.” I always raised the issue of what motivated the appropriation of public funds in the first place. It is not enough to, as Stan Moberly said, “steal up to the back door” and leave your findings in the middle of the night so someone might find them when picking up the morning milk.”
Yes thx, Richard; feel free to contact me (see https://www.researchgate.net/profile/Robert_Vadas). I’ve long thought about WOTUS issues since being a grad. student at VA Tech. And what we’ve had since the Bush Sr. admin. is a political seesaw for it, reflecting more vs. less paying attn. to the sci. behind it. But not crapping in one’s own bed shouldn’t be a partisan issue.
Yes Paul, nice to hear from you again! I remember you speaking to us at VA Tech about promoting advocacy w/in AFS, something that has taken a few more decades in finally getting a strong statement on the lower Snake R. dams: Winters, D.B., ed. 2023. Statement of the American Fisheries Society (AFS) and the Western Division of AFS about the need to breach the four dams on the lower Snake River. Fisheries 48: 215-217 [cf. https://fisheries.org/policy-media/recent-policy-statements/statement-of-the-american-fisheries-society-afs-and-the-western-division-afs-wdafs-about-the-need-to-breach-the-four-dams-on-the-lower-snake-river/%5D
I certainly took your advice to heart during that WDAFS project!
A government employee who is hired for some degree of knowledge about a topic should first of all let the agency know where the employee thinks the agency is erring. Having done so, the employee is an employee, not a slave, and has a citizen’s rights to share technical knowledge and perceptions with others who have similar interests and concerns. The agency has an obligation to consider knowledge, but agencies also have to balance conflicting facts and interests and concerns. The employee would do well to try to understand any balancing the agency is doing, and may use that understanding to further try to modify the agency position. If that is not successful, it is reasonable for the employee to work more with those other parties with shared interests. (Fortunately, I was comfortable with the policies of the agency that employed me.)
Well said, Hal B., but I do remember you grousing about agency-hatchery policy a time or 2… 🙂
Y’all might find this rept. to be of interest re: state natural-resource conflicts:
WDRC (William D. Ruckelshaus Center). 2024. Washington Department of Fish and Wildlife: organizational review final report. Prepared for the Washington State Legislature. Olympia, WA. 56 pp. & app. (https://wdfw.wa.gov/sites/default/files/2024-12/wdfw-organizational-review-final-report.pdf).
Hal, I strongly agree with you posted. The issue for me is one of degrees….how far can a government employee go in opposing something. I am of the opinion (likely not a popular one) that an employee discovering something not in line with agency policies, illegal, or not scientifically supported, then that person should be allowed to leak such information and provide the context and rationale for opposing whatever is being reported or done. The employee should be able to do so anonymously or through the whistle-blower route. Of course IG’s are being eliminated under the new administration, so what I am proposing may no longer have any support or even be logical. Without question, it is a very tricky. road to follow.
Here’s a laudable whistleblowing event from my grad.-student days. Despite fed. study of potential listing of 2 forage fishes (including Roanoke logperch) in VA (Biggins 1980), the process stalled ‘til the muzzled Burkhead (1983) went public to get VA Tech involved w/ research studies on both spp., which finally led to a recovery plan for the logperch (Moser 1992) when I was there. VA Tech would again help w/ whistleblowing research for tragic Flint’s water scandal.
There is a push to pardon Edward Snowden now, but overall I think the Trump admin. will be killing messengers, we’ll see…
Biggins, R. 1980. Endangered and threatened wildlife and plants: review of the status of the orangefin madtom (Noturus gilberti) and the Roanoke logperch (Percina rex). Federal Register 45: 31447 31448 (https://archives.federalregister.gov/issue_slice/1980/5/13/31446-31448.pdf).
Burkhead, N.M. 1983. Ecological studies of two potentially threatened fishes (the orangefin madtom, Noturus gilberti and the Roanoke logperch, Percina rex) endemic to the Roanoke River drainage. Prepared for the Wilmington District Corps of Engineers. Wilmington, NC. 115 pp.
Moser, G.A. 1992. Roanoke logperch (Percina rex) recovery plan. Annapolis
Field Office, U.S. Fish and Wildlife Service, Region 5. Annapolis, MD.
22 pp. (https://drive.google.com/file/d/1D6yW0Kib_LQ9QqAdTwJfB_efwTdWvSO3/view).