Public Comments Processing
Attn: FWS-R8-ES-2014-0058
U.S. Fish and Wildlife Service Headquarters, MS: BPHC
5275 Leesburg Pike
Falls Church, VA 22041-3803
Or submit online at:
http://www.regulations.gov/#!submitComment;D=FWS-R8-ES-2014-0058-0001
To the U.S. Department of Interior:
Writing on behalf of [chapter name] and its XX members and supporters in
[location], I am writing to express our organization’s opposition to the current effort
to remove the Coastal California Gnatcatcher from the protections it currently
enjoys under the Endangered Species Act. It is our firm belief, shared by most in the
scientific and conservation community, that the Coastal California Gnatcatcher
should retain its Threatened status under the Endangered Species Act.
[Specific local information, ie, “The California Gnatcatcher has special importance to
our members because …]
The fact that the Coastal California Gnatcatcher is a distinct subspecies worthy of
protection was established in 1993 at the time of the original listing, and
subsequently confirmed by an expert panel convened by the U.S. Fish & Wildlife
Service in 2004 and there's nothing in this latest petition that casts doubt on that
determination. One study, supported by Southern California builders who stand to
gain financially from a delisting, should not be enough to overturn more than a
hundred years of objective research to the contrary.
In particular, the study that the petitioners rely upon has substantial limitations.
While it purports to be the final word on DNA evidence, it is far from conclusive on
the subject of the Coastal California Gnatcatcher's status as a subspecies. As many
researchers in this field have noted, the nuclear DNA data analyzed for this study is
not nearly sufficient to conclude that the bird is not a distinct subspecies, and
actually avoids data that would indicate distinctiveness.
The study also fails to provide sufficient morphological and ecological data of what
would be necessary to reject a subspecies designation.
Also, I would also note ongoing threats to the Coastal California Gnatcatcher. Despite
the bird’s Threatened status, large portions of the bird's range do not have habitat
conservation plans in place. It is important to understand that the threats that
existed at the time of the listing remain unabated. These threats include habitat loss
from development, repetitive fires that have destroyed much coastal sage scrub
across its range, and invasive vegetation.
[If the chapter has particular interest in coastal sage scrub, include it here, or just go
with the section below]
The Coastal California Gnatcatcher is an essential part of a Southern California
ecology that is rapidly diminishing. Not only is the California Gnatcatcher a
magnificent bird worthy of protection, it is also emblematic of the rich coastal sage
scrub of southern California, an enduring remnant of our wild coast that is now the
most endangered habitat type in North America. Some researchers estimate that as
little as 10 percent of California's original coastal sage scrub habitat remains today.
Again, our organization encourages the U.S. Department of Interior and the U.S. Fish
& Wildlife Service to deny this petition to remove the Coastal California
Gnatcatcher's Threatened status under the Endangered Species Act.
Sincerely,
Name
Title
Chapter name