I urge the rejection of this proposed rule.
I think we can be very thankful for the definition of harm as currently defined. If we were talking about the human species there would be no doubt that significant degradation of our ability to feed, shelter, and produce offspring would indeed be considered harm.
From only an economic perspective this proposed rule change is extremely counter productive. We learn an enormous amount from animals and that knowledge creates enormous economic value.
An example is the horseshoe crab. The Virginia Institute of Marine Science estimates the value of horseshoe crabs to the medical research industry at $100M per year. In 2023, the US Fish and Wildlife Service began work to aid their reproduction and support this industry. If harm is no longer defined as a significant decline in ability to reproduce, will we be able to protect this industry?
As our technology advances we are always learning more from animals, so we don't know which animals will give us our next billion dollar industry. After we decimate a species, we may not get to choose if it goes extinct, and with each extinct species we inflict immense harm on current and future generations of humans.