Comment on FR Doc # N/A

Wright's Field is a large native grassland in Alpine, CA, designated as a pre-approved mitigation area of the County of San Diego's MSCP. The Back Country Land Trust owns 230 acres of this ~400 acre area, and is working to acquire the rest. The native grassland contains ideal habitat for the Quino checkerspot butterfly (QCB). I request that the proposed Critical Habitat designation be amended to include Wright's Field because: 1. adult Quino butterflies have been observed for 3 years SE of Tavern Road, Alpine, within ~3 km of Wright's Field. 2. the habitat is ideal with an abundance of the host plant Plantago erecta, as observed by Allison Anderson of the USFWS Carlsbad, CA office during a visit and exploratory walk-through in the spring of 2005. 3. Wright's Field provides connectivity for core QCB populations to the south within the Otay Occurrence Complex, which includes Rancho Jamul and Hollenbeck Canyon. 4. Critical Habitat designation would facilitate a recovery plan because (a) the land is designated in the PAMA of the MSCP, and (b) 230 acres is already owned by the Back Country Land Trust, which has the goal of acquiring a remaining ~140 acres. Both the County and Land Trust would be able to contribute oversight and labor necessary to implement a recovery plan. The recovery of endangered species is a key requirement of the ESA. 5. Surveys are on-going each year by professional biologists, licensed by USFWS to conduct surveys for the QCB. Hence, the QCB could be discovered at any time, and the Critical Habitat designation would become deficient without inclusion of Wright's Field. Supporting information is attached: 1. A nine page report summarizing four visits as an informal survey conducted by expert biologist, Viviane Marquez, in 2005, indicating the potential for the QCB in Wright's Field, and the potential for a recovery project. This report concludes that: "The 372-acre Wright?s Field MSCP Preserve in Alpine, California, appears excellent for supporting a large population of QCB." 2. Photographs of Plantago erecta in Wright's Field, which is abundant and distributed through the ~180 acres of native grassland (other habitats are coastal sage scrub, vernal pool, and Engelmann oak woodland). Thank you for your consideration of these comments. C. D. Stout Back Country Land Trust March 16, 2008