The Tumbling Creek Cavesnail is a very unique species for which the highest degree of protection should be extended.
One of the major concerns is the groundwater system influenced by the Bull Shoals Lake. The lake inundates springs and as as result presumably decreases flow rates under at least parts of the critical habitat of the species. The effects of decreasing velocity are well known, increasing sediment deposition, as well as potentially decreasing dissolved oxygen levels. It is of note also that the document has what appears to be an error concerning dissolved oxygen, i.e., the specified level of 4.5 mg/l should be the level at which it should not be lower (the document says not to exceed, which is the opposite). Presumably a typo but important to correct.
Another concern is that this cavesnail has evolved in an environment rich in bat guano. With White Nose Syndrome in bats now confirmed in Missouri I have concern about the potential change in nutrient input into the system if the bats are decimated in the cave, or even extirpated. A great deal of emphasis has been placed, correctly, on the extirpation of bats from WNS, but that said, the USFWS needs to focus more on the other members of the cave communities that are just as dependent upon the presence of bats.
Comment on FR Doc # 2010-15252
This is comment on Proposed Rule
Endangered and Threatened Wildlife and Plants: Designation of Critical Habitat for Tumbling Creek Cavesnail
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