Submitted Electronically via eRulemaking Portal

The Dept of Fish & Wildlife has not provided evidence of sound scientific methods used in determining the proposed listing of White Bluffs Bladderpod as a subspecies. All evidence presented relies solely on phenotypic evaluation. There is no doubt in the scientific community that the physical environment of an organism can produce radically different phenotypes. The only way to definitively declare a subspecies is to perform DNA analysis. Two of the authors cited in the listing believe it is not a subspecies but an ecotype. This appears to be a rush to declare the species due to pressure applied by the Center for Biological Diversity (CFBD). It is alarming that a group such as CFBD can trump informed decisions using scientific methods and trample the rights of private property owners! The inclusion of private property in the proposed critical habitat area is unwarranted. Any listing will have an impact on the economy of the region. There has been limited research and questionable conclusions on impact to customs and culture of the region in the proposed rule. We strongly recommend the Agency conduct unbiased, balanced studies based on science and not allow the CFBD to force the Agency into a rushed decision. A threat of a lawsuit from CFBD or any other group does not release the Agency from the obligation to perform good science!