A decision made by the Endangered Species Committee, colloquially known as “The God Squad,” can lead to the survival or the extinction of a species. By law, the God Squad only meets when an applicant seeks a major exemption to the Endangered Species Act to move forward with a project or program likely to lead to a species’ extinction. It’s a rare occurrence. In fact, the committee has only been convened three times since the process was established in 1978. It can only lawfully convene to consider an application for an exemption after:
- A project is officially found to be likely to jeopardize a species’ survival and recovery, i.e., lead to its extinction;
- A timely exemption application has gone through preliminary review by the Secretary of Interior; and
- There has been a formal, on-the-record hearing in front of an administrative law judge.
What is the God Squad?
Enacted in 1973, the ESA is the strongest legislation ever enacted anywhere in the world to protect and recover threatened and endangered species. Its powerful protections have directly led to its 99% success rate, meaning it has saved 99% of listed species from extinction. The ESA enjoys widespread bipartisan support among the American people, who treasure our shared national wildlife heritage.
One reason for the ESA’s stunning success is Congress’ directive that all federal agencies must avoid taking any actions likely to jeopardize the continued existence of any listed species or that will destroy or adversely modify listed species’ critical habitat. To fulfill this mandate, these “action agencies” consult with either or both of two expert wildlife agencies — the U.S. Fish and Wildlife Service and the National Marine Fisheries Service — regarding the effects of the action on listed species and designated critical habitat.
Most of the time these consultations are completed informally, such as by email or phone calls. Some of the time, formal consultation is required, resulting in a biological opinion by the expert wildlife agency that determines “likely jeopardy” or “no jeopardy.” Only a tiny fraction of formal biological opinions result in a jeopardy finding, because the action agency, wildlife agency and permit applicant, if any, figure out ways to enable the action to proceed without jeopardy. Even in the very rare case of a formal jeopardy opinion, the wildlife agency strives to come up with a workable alternative (a “reasonable and prudent alternative”) that will enable the action to proceed and avoid jeopardy.
Hence, Endangered Species Committee meetings to vote on exemption applications are extremely rare. They have only happened three times in nearly 50 years, because of how rare it is to have a “jeopardy” biological opinion without a reasonable and prudent alternative that is acceptable to the action agency.
The committee is entrusted with the power to decide whether a federal action is so important that it clearly outweighs the survival and recovery of the species at issue and merits an ESA exemption. This power over a species’ survival or extinction earned it the “God Squad” moniker.
Who is on the God Squad?
The six permanent members of the God Squad are:
- The Secretary of the Interior (who serves as the chair)
- The Secretary of Agriculture
- The Secretary of the Army
- The Chairman of the Council of Economic Advisors
- The Administrator of the Environmental Protection Agency
- The Administrator of the National Oceanic and Atmospheric Administration
The seventh member is designated by the president and is an individual from the affected state. If multiple states are involved, they will each be represented but will only receive a fraction of the seventh vote. The God Squad may only grant an exemption by vote of five or more committee members.
When has the God Squad voted?
In 1978, a U.S. Supreme Court decision halted the construction of the Tellico Dam in Tennessee because closing the dam’s floodgates would wipe out a tiny, endangered fish called the snail darter (Percina tanasi). In response, Congress amended the ESA to set up the God Squad process. The God Squad reviewed the Tellico Dam project's application for an exemption and voted for the snail darter’s survival by rejecting it. Congress then passed legislation to enable the dam to be completed.
Around the same time as Tellico, the God Squad met to review an exemption application concerning the Grayrocks Dam in Wyoming and endangered whooping cranes downstream in Nebraska. The Grayrocks Dam was being built on the Laramie River, a tributary of the Platte River, in Wyoming. The dam’s water diversion would destroy the crane’s critical habitat downstream in Nebraska. The God Squad voted against saving the cranes, but their vote came with caveats required by the ESA. There were limits and rules around water use and timing of releases, and the agency had to pay for whooping crane habitat conservation in other areas on the Platte River. Whooping cranes are still listed as endangered under the ESA today.
The last time the God Squad voted was in 1992. The Bureau of Land Management wanted to proceed with 175 timber sales on old-growth forest in western Oregon. This old-growth forest was habitat for threatened northern spotted owls and contained designated critical habitat. FWS found jeopardy for 44 out of the 175 sales. The God Squad voted to permit 13 of the 44 sales. Defenders of Wildlife and other environmental groups successfully challenged this decision in federal court. The Ninth Circuit Court of Appeals found the White House had illegally engaged in secret communications with the God Squad to try to influence the vote. This violated legal requirements that the public must be able to attend all committee meetings and have access to all committee records. Two months later, BLM withdrew its exemption request and eventually withdrew the sales from its timber program. Northern spotted owls are still listed as threatened under the ESA today.
Why is the God Squad convening for a fourth time and is it legal?
With only two weeks’ notice, the God Squad has just been scheduled to meet on March 31, 2026. Secretary of the Interior Doug Burgum is holding a snap meeting of the God Squad to further the goals of President Trump’s executive order declaring a fictitious “national energy emergency,” issued on Day One of his administration. The Federal Register meeting announcement states the committee will consider an ESA exemption for oil and gas activities the Department of Interior manages in the Gulf of Mexico.
But the God Squad cannot legally vote on any such exemption application because Interior has failed to follow any of the ESA’s detailed procedures for teeing up an exemption for a God Squad vote. Because this meeting is so unprecedented, and the Secretary has shared no information publicly, it is impossible to know what the God Squad might do.
Wildlife in the Crosshairs
The God Squad may illegally attempt to hand out an extinction notice to the critically endangered Rice’s whale, which numbers only 51 individuals, and whose only home is the Gulf of Mexico. A May 2025 formal consultation found that vessel strikes by oil and gas vessels will likely jeopardize the species, but that workable alternatives exist to avoid jeopardy.
The God Squad may also illegally attempt to hand out a broader blank check to the Interior Department to avoid the ESAs requirement to consult on these oil and gas activities. This would remove protections for many other threatened and endangered species affected by these activities, such as the endangered sperm whale and five sea turtle species. Needless to say, the ESA doesn’t allow any such blank check.
We simply do not know what the God Squad intends to do, because true to form, this administration treats the law like a suggestion it can ignore at will. No administration, Republican or Democrat, has ever pulled a move like this before. But we do know any exemptions the God Squad purports to grant will be flatly unlawful.
The Trump administration has imperiled American wildlife firmly in its sights. The same executive order declaring the fake “energy emergency” directed the God Squad to meet quarterly to identify “obstacles” to domestic energy posed by the very laws protecting endangered and threatened species and marine mammals. The Interior Department and Army Corps of Engineers are unlawfully enabling “emergency consultations” to allow energy projects to proceed without ESA compliance. The administration has put forth multiple proposals to weaken the ESA’s implementation. The list goes on. When Big Oil and its extractive industry cronies ask the Trump administration to jump, the only question the administration asks is how high. Our national wildlife laws — and our precious national wildlife heritage — simply do not matter to them.
What can you do?
The Trump administration is illegally asking the Endangered Species Committee to play God. If the committee votes to allow oil and gas activities in the Gulf of Mexico to proceed without endangered species protections, this could cause the only whale endemic to America to go extinct and have disastrous consequences for other listed species as well. Wildlife in the Gulf of Mexico has already suffered the consequences of decades of poorly regulated fossil fuel extraction. This includes the catastrophic 2010 Deepwater Horizon oil spill, one of the largest environmental disasters in world history and a prime example of what’s at stake when we run roughshod over laws designed to protect people and wildlife.
You can help by joining us in making your voice heard by signing our petition to Secretary Burgum to opposing the illegal use of the God Squad.
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