Comment on FR Doc # E9-09164

See attached document for full comments. To Whom It May Concern, In addition to the Hiawatha National Forest that the National Resources Defense Council (“NRDC”) suggests to be designated as critical habitat for the Hine’s Emerald Dragonfly, the Michigan Nature Association (MNA) would like to require the following three areas also to be designated as critical habitat: The Lennagene Rossman Stratton Memorial (“The Stratton Memorial”), The Peter Memorial, and Mystery Valley. Specifically, those three areas of land are located as follow: T 42N., R4W., Sec. 31 in Brevort Township, Mackinac County; T 31N., R9E., Sec. 4 in Alpena Township, Alpena County; and T 33N., R6E., Sec. 32 in Posen Township, Presque Isle County; respectively. The inclusion of the Stratton Memorial is especially important because it falls directly under the argument the NRDC made concerning the addition of private land that lies adjacent to the Hiawatha National Forest (5). The reasons for designating The Stratton Memorial are applicable to the other two areas aforementioned; thus, justifying their designation as critical habitats as well. The Stratton Memorial, a piece of land that is located near Brevort Lake, MI falls under many stipulations required by the FWS when a piece of land is considered for critical habitat. First, it possesses all the necessary PCEs required to be a critical habitat for the Hine’s Emerald Dragonfly. Some of these PCEs include imperative geological and hydrological features, such as water flowing through limestone and tufa rock, which creates habitat for the federally endangered dragonfly (Emmi and Plater 2004). As delineated in the Endangered Species Act (“ESA”), 16 U.S.C. § 1532(5)(A)(i), these geological features mandate that this area of land be designated as critical habitat. It states that critical habitat is “[the] specific areas within the geographical area occupied by the species” which contain “physical or biological features (I) essential to the conservation of species and (II) which may require special management considerations or protection.” The reason these natural features mandate designation as critical habitat is that the primary threat to the Hine’s emerald dragonfly is habitat destruction (U.S. Fish & Wildlife Service). The specific habitat that the Hine’s Emerald Dragonfly requires is so delicate that the greatest protection available is necessary to maintain the fragile components. Any sort of disturbance, which can range from large urban development to minute contamination due to local waste, can drastically damage already exiguous habitat area (U.S. Fish and Wildlife Service 2006). This vast range of potentiality demonstrates the vital necessity for the land to be classified as critical habitat. One alarming fact to consider is any degree of alteration to channels in the wetland systems can affect breeding habitat. Wetland systems are especially important to the life cycle of the Hine’s Emerald Dragonfly because the larvae require the shallow water to develop and feed (U.S. Fish & Wildlife Service). This fact warrants the designation of the three proposed MNA lands because even though they may be outside of current considered lands, they all have and contribute to channels in the dragonfly’s breeding habitat. This is especially true for the Stratton Memorial, which has numerous channels that directly feed into the Hiawatha wetland system. In addition to being required by law, it’s only logical that if available land has the potential to be designated as critical habitat, that it in fact be designated and not left unprotected, resulting in potential loss and endangerment of the dragonfly. These three pieces of land are small enough in size that no significant cost would be gained, and no possible partnerships or efforts would be put in jeopardy if these lands were to be designated as critical habitat. It would only help. The MNA greatly appreciates and lauds the actions of the Service to reconsider the designation of the Hiawatha National Forest as a critical habitat. Such a large area of land protected would provide better security and insurance to the proliferation and survival of the Hine’s Emerald Dragonfly. Besides the individual biological and physical merits that The Stratton Memorial possesses, its adjacent location to the Hiawatha National Forest only further legitimizes its designation as a critical habitat. In laymen’s terms, The Stratton Memorial as critical habitat would be like increasing the size of the Hiawatha National Forest in terms of the dragonfly’s protection. Again, simple logic underlies the protection of the Hine’s Emerald Dragonfly. In regards to the previous statement, the NRDC also makes an argument in favor of designating private land. History has shown that the FWS is not particular to involving itself with privately owned land(Wetzler and Fallon 2009). However, MNA and its constituent members would like to state that we fully support and believe in the designation of our three pieces of land as critical habitat. We feel that the benefits that will result following the designation will maintain the lands and show the support of the FWS for the work that we do. With that being said, the support for private lands being designated accompanied by the understanding of required biological and physical characteristics needed for the Hine’s Emerald Dragonfly require the designation of the other two lands mentioned in the beginning, the Peter Memorial and Mystery Valley. These two sections of private land are found in Alpena County and Presque Isle, respectively. Research and fieldwork have shown that the dragonfly does make its habitat in these two counties in addition to Mackinac County, where Hiawatha National Forest and The Stratton Memorial are found. These two areas have very similar biological and physical characteristics that require greater protection to ensure that the dragonfly’s survival is guaranteed. It may be argued, like in the original Final Rule, according to 16. U.S.C. § 1533(b)(2), that the costs of designating these two other areas as critical habitats may outweigh the potential gains, which allows the Secretary to exclude them, unless their exclusion will result in the extinction of the creature(Wetzler and Fallon 2009). Based on the provided evidence and factual information, excluding any land that the Hine’s Emerald Dragonfly may utilize would certainly place this creature in serious jeopardy. To summarize, the MNA strongly recommends that the FWS designate The Stratton Memorial, The Peter Memorial, and Mystery Valley as critical habitat for the Hine’s Emerald Dragonfly. With habitat loss being the most pressing issue facing this endangered species, the addition of any more land to the status of critical habitat greatly reduces the possibility of losing this dragonfly for good. The circumstances that these lands currently possess make them ideal, logical, and necessary factors to consider when reevaluating the Final Decision. Jeremy Emmi Executive Director Michigan Nature Association Michael Breish Michigan Nature Association Statewide Steward Works Cited Emmi, Jeremy, and Brent Plater. "Lawsuit to Protect Hine's Emerald Dragonfly Settles Successfully." Michigan Nature Association Newsletter, October 2004. U.S. Fish & Wildlife Service. "Hine's Emerald Dragonfly." Threatened and Endangered Species, March 2006. U.S. Fish and Wildlife Service. "Summary of the Proposal to Designate Critical Habitat for the Hine's Emerald Dragonfly." Summary of Proposal, Department of the Interior, U.S. Fish and Wildlife Service, 2006. Wetzler, Andrew, and Ph. D., Sylvia Fallon. "Revised Critical Habitat for the HIne's Emerald Dragonfly." Public Comments Processing. Chicago, Illinois: Natural Resources Defense Council, June 22, 2009.