Submitted Electronically via eRulemaking Portal

1. The draft economic assessment addresses the potential economic impacts of critical habitat designation for the streaked horned lark, Taylor's checkerspot butterfly, and four subspecies of the Mazama pocket gopher in Oregon and Washington to be $793,574 between the years 2013-2033. If the port could not place dredge material at one of its designated upland placement sites due to the presence or potential presence of the streaked horned lark, the cost to dispose of that material could exceed that cost within just 1-2 years of dredging. Although the port's dredge material placement sites are not proposed for critical habitat designation, the USFWS may consider these sites suitable, and Sandy Island is proposed for designation directly across from the port. The designation of critical habitat directly across from the port, could attract the streaked horned lark to the port, which is a location for active industrial activities. The port requests consideration of the operational and development limitations that could occur at the port with this designation. 2. The primary constituent elements and characteristics for habitat suitability for the streaked horned lark are fairly specific, yet habitat will change over time, and perhaps be suitable for only a limited period of time due to vegetation growth. Will critical habitat designations be time limited or adjusted periodically? 3. Dredge placement sites are human made and/or managed features, and not "naturally occurring habitat." Dredge material placement sites are specifically created for the placement of dredge materials and these sites are managed as such. The port needs to maintain full access to its dredge material sites. Limitations on use of these sites could increase operations and maintenance costs for the port. Thank you for considering these comments on behalf of the Port of Kalama. Sincerely, Tabitha Reeder On behalf of the Port of Kalama