Public Comments Processing
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 North Fairfax Drive MS 2042-PDM
Arlington, VA 22203
Reference: Draft Economic Analysis, Proposed Critical Habitat Designation for the Mountain Yellow-Legged Frog, Sierra Nevada Mountain Yellow-Legged Frog and the Yosemite Toad
Dear Sir or Madam:
The subject draft economic analysis is sorely lacking. There can be little argument that the designation of critical habitat as proposed, particularly that for Yellow-Legged Frogs, will have a dramatic effect on the economy of the eastern Sierra. Your agency needs, and the residents of this area deserve, an accurate analysis of those impacts so that the critical habitat decision can be made with a full understanding of its effects. The public deserves an honest debate of the cost of and need for this proposal – a debate your agency seems determined to avoid.
By the terms of your own proposal, yellow-legged frog critical habitat will not contain trout. Yet most waters in the proposed hundreds of thousands of acres of proposed critical habitat contain trout and support a healthy recreation economy. That economic activity is directly dependent on healthy populations of fish. As the trout go, so will the economy. Your agency’s draft economic analysis completely and purposefully ignores this huge and predictable impact to the economy of our area. This does not accord with the Endangered Species Act, the National Environmental Policy Act or the Administrative Procedure Act. More importantly, it does not accord with common sense or any fair or impartial standard for federal decision-making.
Your agency proposes making a designation that has a high likelihood of severely affecting the livelihoods and lifestyles of this area’s inhabitants. It is inexcusable to make such a decision while intentionally avoiding consideration of the impacts of the decision and ignoring all those whose lives will be affected. To purposefully avoid honest debate on the merits of this decision is not only poor policy, it is poor governm