Submitted Electronically via eRulemaking Portal

The State of Utah has reviewed the proposed listing for Coral Pink Sand Dunes tiger beetle as endangered under the provisions of the Endangered Species Act (ESA) as well as the designation of critical habitat and associated draft economic analysis (DEA) and draft environmental assessment. The state does not agree that listing the species and designating critical habitat is necessary to ensure the species protection. Initially formalized in 1997, and revised only three years ago in 2009, the Conservation Agreement and Strategy for the Coral Pink Sand Dunes Tiger Beetle (CA&S) is an established and ongoing partnership for collaboration and implementation of conservation measures to protect the beetle and its habitat under an adaptive management framework. The purpose of this partnership is “to ensure the long-term persistence of Coral Pink Sand Dunes tiger beetle within its historic range and provide a framework for future conservation efforts.” The Utah Department of Natural Resources, Division of Parks and Recreation, in concert with the U.S. Department of the Interior’s, Bureau of Land Management (BLM) and Fish and Wildlife Service (Service), and Kane County, Utah, has been involved in this collaboration and voluntarily implemented conservation actions to benefit the Coral Pink Sand Dunes tiger beetle and its habitat, monitored their effectiveness, and adapted strategies as new information became available. A summary of accomplishments under the CA&S include: 1. The establishment of two conservation areas where Off Highway Vehicle (OHV) use is restricted has protected beetles from this threat. OHV’s are not allowed in these areas and State Park and BLM staff enforce this restriction. The conservation areas protect the majority of beetles from OHV impacts. 2. Annual monitoring of the population and habitat has continued. 3. Research efforts have clearly defined the lifecycle of the beetle and indicate that limited rainfall is responsible for observed pop