Submitted Electronically via eRulemaking Portal

Re:Proposal to designate critical habitat for the CPSD tiger beetle. As a 14 year resident of Kanab, I visit the CPSD Dunes often. Based on my observations of OHV use there, I think designated critical habitat should include all known and potential CPSD tiger beetle habitat in the dunes, including dispersal corridors between Conservation Areas A and B.Although the updated Conservation Agreement expands protected areas and provides for habitat dispersal corridors delineated by carsonite signs, these modifications may not be adequate to prevent OHV disturbance. In fact, a designated Special Recreation Management Area for intensive OHV use is located in or near the dispersal corridor between the two protected conservation areas. Carsonite signs have proven inadequate to limit OHV activity at CPSD. Compliance with existing sign barriers is lax at times and it’s likely that new barriers won’t always be observed. Enforcement is difficult due to staffing shortages and budget cuts may exacerbate this problem. Designation and fencing of critical habitat is necessary to protect the swales of suitable habitat and dispersal corridors outside the conservation areas. The tiger beetle is under threat from the cumulative effects of off-road vehicle use, drought, climate change, and the failure of existing regulatory mechanisms to adequately protect the species and its habitat. The FWS should take any and all actions necessary to ensure the survival of the species as a priority over recreational uses. There are hundreds of miles of roads available for OHV activity in the area, so recreational use won’t be impacted overall. The Draft Economic Analysis shows that critical habitat protections will have a minimal effect on the economy. Given the threats to the species, protecting all available critical habitat would have a minimal effect on OHV recreation and may have a major impact on ensuring the persistence of the tiger beetle. Thank you for the opportunity to comment.