Comment on FR Doc # 2010-31227

I am writing to generally support the proposal by the FWS to designate critical habitat for Rana sevosa. I conducted research on this species from 1992-2001 and published or co-authored many of the papers and reports cited in this proposal. Briefly, data collected by myself and numerous colleagues from 1992-2010 indicate that this species is one of the most endangered (if not the MOST endangered) species of amphibian in the US. Given the low number of populations, significant recent habitat disturbance, presence of a known fatal disease, and the imminent construction of a major housing development immediately adjacent to the only known viable population, designation of critical habitat is essential to avoid extinction in the wild. This being said, I do have one strong reservation concerning the size of the so-called “buffer zones” surrounding known breeding ponds (see text quoted below). The proposed size of these buffer zones (350 m) is almost certainly inadequate for protection of the majority of frogs in a viable population. As indicated below, this size was arrived at by FWS using the data published by Stephen Richter and myself in 2001, but the proposal fails to acknowledge that this paper specifically noted that the movements of the frogs in that study were almost certainly truncated by the presence of a very recent clear-cut of the forest immediately adjacent to the pond (Richter et al., 2001, pp 320). Furthermore, the same paper specifically recommended a buffer zone of 1000 m, not the 350 m in the current proposal. I argue that using the movement data from Richter et al (2001) without properly acknowledging the restrictions of the study indicated by the authors themselves is entirely inappropriate. The FWS should be following the best published scientific data available and the single publication on movements of Rana sevosa recommended the use of a 1000 m buffer zone, not the 350 m in the current proposal.