Submitted Electronically via eRulemaking Portal

I support listings for the four gopher subspecies, the streaked horned lark, and the Edith's checkerspot butterfly. I would comment specifically on the streaked horned lark and its management on McChord Field as I work extensively there. Flying operations there seem to have little impact on the population; the impact seems to come from landscape management of the airfield. Base authorities have the impression that FAA regulations require maintaining vegetation at 7" to 14" in height. This requires the airfield be mowed continuously throughout the growing season and while the birds are present. This obviously results in destroyed nests and possibly direct death of birds. At the same time McChord's airfield has an extensive infestation of spotted knapweed (Centaurea stoebe L. subsp. micranthos (Gugler) Hayek), which is listed as a noxious weed and must therefore be controlled. Unfortunately, chemical control is the only practical means of controlling the weed, and application must be done post-germination and prior to flowering - a time that overlaps the birds' nesting season. For this reason, it seems to make sense that the best answer for protecting the birds is to translocate them to appropriate habitat elsewhere. How to accomplish this poses a significant challenge, given the birds' strong location fidelity, but it appears unlikely the challenge can be met without the protections afforded by listing.