Comment on FR Doc # 2010-00323

Thank you for the opportunity to comment on the proposed Critical Habitat Designation for Limnanthes floccosa ssp. grandiflora and Lomatium cookii. I am writing in support of critical habitat designation for these species. I am particularly familiar with Lomatium cookii through long term population studies I have conducted on this species as well as experiments with reintroduction techniques designed to support recovery efforts and restoration. I find the critical habitats mapped for the species in this proposal to be a generally valid portrayal of the species’ habitat distribution. I suggest that the critical habitat for both species should also include population areas discovered after 3 years post-listing (page 37322) because all populations that are currently known, not just those found within 3 years of listing, were almost certainly present at the time of listing. For both species, dispersal is very limited and establishment after dispersal is likely to be infrequent. Therefore, use of all known populations to designate critical habitat is warranted, and a revision to these methods in the proposed rule should be considered. The proposed rule suggests that mining is generally not a significant threat to Lomatium cookii (page 37316). In Jackson County, however, mining may be the greatest immediate threat to this species. Mining claims have been active in this are in the last 20 years and continue to be explored and pursued. The largest population of this species occurs at French Flat ACEC in an area subject to mining in the near term. I believe the text of the proposed rule should be modified to include this threat as critical, instead of generally not an issue. Thank you very much for the opportunity to comment. If you have any questions, please feel free to contact me.