Comment on FR Doc # E9-09141

May 3, 2009 Public Comments Processing: Attention: FWSRIN 1018-AV90 Division of Policy and Directives Management USFWS 4401 N. Fairfax Drive Suite 222 Arlington, VA 22203 Dear FWS: I understand from a news article in our local newspaper that comments for California red-legged frog critical habitat designation can be accepted through May 28, 2009. My comments, as listed below, are specifically for the Solano County, California areas SOL-1, SOL-2 and SOL-3, but may also be applied to other designated areas. I am in agreement with the extended critical habitat designations as published in the Federal Register Vol 73, No. 180 dated Tuesday, September 16, 2008 for Solano County and Federal Register / Vol. 74, No. 80 / Tuesday, April 28, 2009. The expanded habitat allows for species adaptability as some portions of the area may be utilized differently in different years. With climate change looming, the species will need all the room they can get to assist with their quick adaptation. The habitat area shown has connectivity through local creeks and streams and covers the upper portions of these watershed areas. I have one suggestion for an addition to SOL-1. South of King Ranch along Lopes Road there are two stock ponds located on property now owned by the City of Santa Clara. These stock pond and associated drainage should be added to critical habitat as they provide a connection between the upland and the Suisun Marsh. Below the stock ponds, a large culvert exists under the I-680 freeway and is a known safe connection for wildlife. I believe area SOL-1 could connect to the protected Suisun Marsh if this piece were added. I would also like to suggest that economic benefit for preservation of amphibians include the value these species provide for mosquito abatement. As we preserve areas for listed amphibians we also preserve the habitat for non-listed amphibians with similar habitat requirements. With the Suisun Marsh so near and the threat of diseases like West Nile, the economic benefits of amphibian mosquito control should be added to any analysis. I do not have quantifiable economic figures on this issue. Within SOL-1, substantial land is owned by the local land trust. With development of public lands under siege by wind and power facilities, it would be useful to somehow ensure that these critical habitat designations not be overridden by presumed “public “benefits for electrical transmission and generation. Item 17 of the April 28, 2009 Federal register is troubling and presumes that energy transmission and generation somehow trump habitat needs for endangered species. The alternatives to using these lands for energy development should be thoroughly investigated by independent means with adequate public disclosure and comment periods. One way to provide assurances is through meaningful recorded conservation easements and support of rangeland aquatic resources through federal and state-funded programs such as USDA’s wildlife habitat improvement programs (WHIP), mitigation through habitat conservation plans, or funded rangeland conservation easement programs. A coordinated effort to rank projects in critical habitat is needed. Existing public land protections will not stand up to energy development that may be pushed through without adequate environmental review. I urge you to look into how additional protections can be placed on lands designated as critical habitat. These comments are provided by me as an individual and do not necessarily reflect the opinions of my employer. Thank you, Susan Wickham 411 Duvall Court Benicia, California 94510