January 5, 2014
Division of Policy and Directives Management, U.S. Fish and Wildlife Service
U.S. Fish & Wildlife Headquarters, MS: BPHC
5275 Leesburg Pike
Falls Church, VA 22041-3803.
Public Comments Processing, Attn: FWS–ES–R8–2013–0011
On behalf of the member governments of the Associated Governments of Northwest Colorado,
we thank you for this opportunity to comment on the U.S. Fish and Wildlife Service’s (USFWS)
proposed critical habitat designation for the Western Yellow Billed Cuckoo (WYBC) within
northwestern Colorado, specifically Units 54 and 55 as depicted on the Colorado pCH maps.
These areas are the outer edges of the WYBC’s natural habitat, and do not support substantial
populations of the species. In fact, there have been only very rare and most often unconfirmed
sightings of the bird in our region. We believe it is extremely premature to consider any critical
habitat designation in these area’s prior to a thorough and complete scientific review of the
WYBC’s actual characteristics, locations, and habitat. We further consider such a designation as
irrational given its slim population in the region and the impacts that such a designation would
have on the local economy. In addition, we agree with the assessment of the Colorado
Department of Natural Resources, who stated that Colorado would be unable to make any
significant contribution to the conservation of the WYBC due to its limited presence and habitat
in the state.
The proposed habitat designation would, however, have significant impacts on many local
economic activities in both areas. The list of potential threats included in the proposal is
extensive, and as such the designation would affect private property adjacent to the designated
terrain, increase costs and regulatory burdens on agricultural operations and non-agricultural
businesses, and negatively impact many activities of local government.
This designation would strongly impact any economic activity or operation adjacent to the
designated habitat that receives federal funding – such as Natural Resource Conservation Service
cost-share grants – or that otherwise holds any nexus with the federal government. This will
primarily effect agricultural producers who seek to engage in operations such as stream bank
stabilization, fencing and grazing management, the installation of irrigation equipment, or weed
control. Producers conducting these and related operations within the area that is proposed to be
designated as critical habitat, would face costly delays, prohibitions, or at the very least
modifications.
While grazing is listed as a threat to the proposed habitat, and the habitat management decisions
that will follow a designation will restrict livestock grazing in the areas, the fact is that most of
the negative impacts of grazing on habitat are from wildlife, not carefully managed grazing of
domestic livestock. This is another way in which our region’s agricultural producers will be
negatively impacted.
These impacts will also be felt by other entities along the proposed areas, both private and
public. The proposed designation will severely limit critical activities such as floodplain clearing,
water diversions, transportation infrastructure maintenance, and gravel pit operations. This will
impose serious burdens on private property owners as well as local governments and the
residents they serve.
Very few of these impacts and financial repercussions were considered in the Economic Impacts
Report attached to the proposal. We strongly believe that before any discussion of habitat
designation be allowed to proceed, an accurate, detailed, and complete analysis of the economic
impacts needs to be completed. The current one is grossly insufficient and fails to make a full
account of the economic consequences and financial impacts associated with the proposal.
In addition, the proposal seems to have left out any acknowledgment of current conservation
efforts underway in the areas in question. A Critical Habitat Designation would ignore or even
jeopardize local efforts such as restoration of riparian areas, and local conservation easements,
activities which would undoubtedly benefit any WYBC who did happen to visit the region.
Finally, the process appears to have suffered by a marked lack of public outreach. We would
strongly recommend that affected private property owners be notified in advance of these
discussions, and that public hearing be held in the places that are most effected – in this case,
Grand Junction and Craig, CO.
In closing, the AGNC opposed this critical habitat designation for the WYBC, and strenuously
requests that A) a full scientific analysis be completed to determine the true extent of the
WYBC’s existence within area’s 54 and 55; B) a complete and accurate analysis of the economic
impacts of a designation be completed; C) current and ongoing local conservation efforts be
acknowledged and accounted for, and D) that greater public input be sought, including
notifications of impacted property owners, and locally-held public hearings.
Thank you for your consideration of our concerns,
Sincerely,
Mike Samson
Chairman, AGNC
Garfield County
Jeff Eskelson
Vice Chairman, AGNC
Rio Blanco County