Comment on FR Doc # 2010-02230

April 5, 2010 Public Comments Processing Attn: FWS-R2-ES-2009-0077 Division of Policy and Directives Management U.S. Fish and Wildlife Service 4401 N. Fairfax Drive Suite 222 Arlington, Virginia 22203 Federal eRulemaking Portal: http://www.regulations.gov Re: Comments on Draft Environmental Assessment for the Establishment of a Nonessential Experimental Population of Sonoran Pronghorn in Southwestern Arizona Dear Sir or Madam: Safari Club International and Safari Club International Foundation (SCI and SCIF) submit these comments in response to the Draft Environmental Assessment for Establishment of a Nonessential Experimental Population of Sonoran Pronghorn in Southwestern Arizona (Draft EA). SCI and SCIF fully support the proposed action, which will hopefully result in a long-term increase in Sonoran pronghorn numbers in the wild as well as the establishment of a second population which is required for the ultimate removal of Sonoran pronghorn from the list of federally designated endangered species. (Draft EA, p. 19) While we endorse the proposed alternative, SCI and SCIF would like to make some additional points and suggestions intended to enhance the proposed management activities. Safari Club International and Safari Club International Foundation Safari Club International, a nonprofit IRC § 501(c)(4) corporation, represents approximately 53,000 members worldwide and promotes the interests of millions of members in the hunting community. Many SCI members and other hunters live in the areas surrounding Kofa National Wildlife Refuge (NWR) and/or recreate in and around the refuge. SCI members hunt and work with state and federal agencies to assist with the conservation of the bighorn sheep that currently live on Kofa NWR. SCI’s missions include the conservation of wildlife, protection of the hunter, and education of the public concerning hunting and its use as a conservation tool. Safari Club International Foundation is a nonprofit IRC § 501(c)(3) corporation. Its missions include the conservation of wildlife, education of the public concerning hunting and its use as a conservation tool, and humanitarian services. More specifically, the conservation mission of SCIF is: (a) to support the conservation of the various species and populations of game animals and other wildlife and the habitats on which they depend; and (b) to demonstrate the importance of hunting as a conservation and management tool in the development, funding and operation of wildlife conservation programs. SCI and SCIF have long supported the U.S. Fish and Wildlife Service (FWS or Service) and the Arizona Game and Fish Department’s (AGFD) efforts to conserve the bighorn sheep population of Kofa NWR. SCI and SCIF joined the FWS and AGFD in litigation to defend against the challenge to the restoration of the Yaqui and McPherson water developments on the refuge. The Reintroduction Should Not Interfere With Existing Hunting Opportunities on the Refuge SCI and SCIF have some concerns that the proposed reintroduction could potentially interfere with existing hunting opportunities for bighorn sheep or other species on Kofa NWR. Hunting on the refuge provides not only excellent recreational opportunities, but also plays a significant role in wildlife conservation. For example, refuge sheep hunting provides important conservation funding and helps to manage the existing population. SCI and SCIF recommend that any Sonoran pronghorn restoration effort be conducted in a way that will not interfere with those existing hunting activities. The Draft EA notes that the FWS plans to establish a buffer zone around the introduction area of about three square miles and also states that in Cabeza Prieta NWR, the FWS has closed areas of pronghorn recovery to public use between March 15 to July 15 each year to minimize human disturbance during the fawning period. SCI and SCIF would not favor a reintroduction if areas currently open to bighorn sheep hunting would have to be closed on the Kofa NWR. SCI and SCIF recommend that the FWS provide additional information about the potential impact that the proposed action will have on existing hunting opportunities and that the Service make every effort to minimize if not eliminate any interference with existing hunting opportunities. Additional Mountain Lion Management is Required The Draft EA notes that mountain lions are a key predator for Sonoran Pronghorn. (Draft EA, p. 13) Although the Draft EA mentions that any mountain lion that finds its way into the breeding pens will be immediately removed, the document specifically states that there is no predator control planned for outside the pens. (Draft EA, p. 75) According to the Draft EA, the Service’s plan is to release up to 20 Sonoran pronghorn from the captive-breeding pen into suitable habitats on Kofa NWR lands adjacent to the pen site, beginning as early as the winter of 2012-2013. (Draft EA, p. 35-36) If the Service plans to release Sonoran pronghorn into the wild, then it should also plan to aggressively control mountain lion in the wild which pose a key threat to the population’s survival. Additional Water Sources Will Greatly Enhance Pronghorn and Bighorn Sheep Survival SCI and SCIF are also pleased to see that the Draft EA contemplates the installation or restoration of several artificial water developments to provide additional water for the reintroduced pronghorn. SCI and SCIF agree with the Service that those water developments will provide necessary water not only to the pronghorn, but also to other refuge wildlife, including desert bighorn sheep. SCI and SCIF take issue with one statement in the Draft EA, which was likely included in error. The Draft EA incorrectly notes that “proposed water developments are unlikely to change community composition or abundance of wildlife species.” (Draft EA, p. 74) To the contrary, the FWS, Arizona Department of Game and Fish, SCI and SCIF and several other groups are currently involved in litigation in the Ninth Circuit Court of Appeals to defend the Service’s restoration of two water sources in Kofa NWR for the purpose that the additional water will reduce malnutrition and dehydration of desert bighorn sheep that currently contributes to reduced sheep populations in the refuge. SCI and SCIF do agree with the Draft EA’s further discussion of water developments and concur that artificial water developments do not contribute to an increase in disease, do not entrap or drown animals and will not increase predation on pronghorn or other wildlife species. In summary, SCI and SCIF support the FWS’s decision to reintroduce a population of Sonoran pronghorn to Kofa NWR, on the condition that the FWS do so in a way that does not interfere with existing hunting opportunities, plans for aggressive mountain lion management, and acknowledges the role that additional water sources play in the health and management of desert wildlife populations. SCI and SCIF appreciate the opportunity provided to comments on this important conservation effort. Please contact Anna Seidman at aseidman@safariclub.org or Doug Burdin at dburdin@safariclub.org, or call 202-543-8733, if you have any questions or we can provide any further assistance. Sincerely, Lawrence Rudolph President, Safari Club International Safari Club International Foundation