Comment on FR Doc # 2011-22990

I applaud the FWS determination that Arctostaphyos franciscana (manzanita) is endangered. I contest the decision not to designate critical habitat. The finding claims (page 22) that no original manzanita habitat remains within San Francisco. In fact, Mt Davidson, one of the original sites of the manzanita listed in the 1958 "A Flora of San Francisco, California," is a Significant Natural Resource Area managed by the Natural Areas Program (NAP) of the San Francisco Recreation and Parks Department. Ten acres of Mt Davidson are original grassland and coastal scrub habitat within which the manzanita was undoubtedly found. Other SNRAs managed by the NAP have equally suitable habitat -- Twin Peaks, Glen Canyon Park, Edgehill Mt Park, and the 15th Avenue Natural Area. Even though historical records from these locations is lacking, there can be little doubt that the manzanita once flourished in all these places, just as it did at Bakers Beach, the Laurel Hill Cemetery, and the Masonic Cemetery. The finding dismisses all nursery trade specimens of the manzanita as of "unknown origin." However, specimens of known provenance are sold by the UC Berkeley Arboretum and at least one reputable native plant nursery, Yerba Buena Nursery. Plants from the latter source have been planted within the Golden Gate Park Arboretum in its native plant section thus validating their legitimacy. I personally have planted two plants from Yerba Buena in my garden adjacent to Mt Davidson in San Francisco. Such specimens from verified sources constitute a vital repository of this species that should not be disregarded by the FWS. The FWS justifies not designating critical habitat by arguing that this would encourage poaching or vandalism of the plant despite the lack of any apparent incentive anyone would have given that it is readily available in the nursery trade. For endangered listing to have any meaningful impact, critical habitat designation is also essential.