Comment on FR Doc # E8-30750

February 9, 2009 Submitted via the Federal Rulemaking portal: http://www.regulations.gov and attached as an MSWord document. Public Comments Processing Attn: FWS-R4-ES-2008-0058 Division of Policy and Directives Management U.S. Fish and Wildlife Service 4401 N. Fairfax Drive Suite 222 Arlington, VA 22203 RE: Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Alabama Sturgeon (Scaphirhynchus suttkusi) Hearing Officer, The Cahaba River Society is a 501(c)(3) non-profit river conservation organization focused on restoring and protecting the Cahaba River. The following comments are offered on behalf of our members. We had forwarded a previous set of comments via the postal service when we understood the comment period closed on January 28th, 2009. Since then, the U.S. Fish and Wildlife Service issued a comment period extension, and the January 28th Public Hearing occurred. Accordingly, we hope we may offer the following additional comments. We were encouraged by at least one comment by the President of the Alabama-Tombigbee Rivers Coalition, Mr. Ralph Clemmons. Specifically, he said, “I think we can work this out.” We certainly hope that is true. During the public hearing, the Coalition brought forth a variety of experts to comment on several concerns they have. We wish to respond to the criticism these experts offered regarding the economic impact that may potentially occur if critical habitat is designated for the Alabama sturgeon. The Alabama-Tombigbee Rivers Coalition hired three experts on economics from Troy State University who spoke at the public hearing. All three gentlemen offered a dire outlook for the impact of designating critical habitat. I am unsure if these are the same authors who predicted an negative impact on Alabama’s economy if the Alabama sturgeon were officially listed as an endangered species. Whether or not they were the same authors, I think it is important to point out that the previous dire predictions by economists hired by the Alabama-Tombigbee Rivers Coalition simply have not occurred as they predicted. Similarly, when the Cahaba shiner, Notropis cahabae, was listed, terrible economic impacts were predicted. Those negative impacts did not occur. Likewise, when eleven freshwater mussels in the Mobile basin were listed, grave economic impacts were predicted. Those negative impacts did not occur. Furthermore, as a general matter, when nearly any species is proposed for protection under the Endangered Species Act, those who oppose the listing cite concerns with respect to severe economic impacts. Such negative impacts rarely actually occur. And here, where no habitat not already currently occupied by the Alabama sturgeon is being proposed for designation as critical habitat, the potential for significant additional economic impact is limited when compared to the potential benefits, as outlined in our previous comments. From our perspective, the assessment by Industrial Economics, Inc., on behalf of the U.S. Fish and Wildlife Service, is a reasonable one, given what can be known at this time. On the other hand, the dire consequences predicted by the Alabama-Tombigbee Rivers Coalition’s economists are not credible, and are, at best, very improbable, as the vast majority of such predictions about the consequences of protecting federally listed species tend to be. Thank you for considering these comments. Sincerely, Randall C. Haddock, PhD Field Director