I am writing to you with my comments regarding Endangered and Threatened Wildlife and Plants: Designation of Critical Habitat for the Polar Bear in the United States (Document ID FWS-R7-ES-2009-0042-0205).
To begin with, listing the polar bear as an endangered species when populations are at near record levels seems disingenuous at best, and particularly distasteful when the basis for the listing is nothing more than a theory. That being said, since polar bears are already listed, these comments are focused on the designation of critical habitat.
The economic analysis showing a cost impact of $669,000 over 29 years is removed from reality. That is an annualized cost of around $23,000. The Service cannot be serious. This listing will further chill the investment climate for any kind of economic activity in the arctic and cripple Alaska’s largest and most vital industry. The impact on the oli and gas industry alone could be in the billions of dollars. The delay of one project for just a few days will blow through $23,000 like a hot knife through butter. The actual economic impact is far more than the Service has proposed and it should be increased to show the reality of the situation. Hundreds of billions would be much more realistic as these designations are likely to stop new exploration and development.
The range of the proposed critical habitat is also unreal. The Proposed Rule defines the largest critical habitat area ever proposed. 200,500 square miles, an area larger than 48 of the 50 U.S. states is greed on an unprecedented basis. For a species that is currently thriving, this is a travesty. The range of critical habitat should not be applied to any area where current economic development is taking place, where villages are located, where traditional hunting areas are located and anywhere where any future economic development will occur.
In closing, please scale scope of the proposal to intersect with something that is far more practic
Comment on FR Doc # 2010-10512
This is comment on Proposed Rule
Endangered and Threatened Wildlife and Plants: Designation of Critical Habitat for the Polar Bear in the United States
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