1. Consider the impacts of leaving nursery trade specimens unlisted. Depending on how the trade is conducted, introgression or other crossbreeding problems may occur. Consider providing these specimens listed status to regulate this threat. There are a discrete number in the trade and it should not be burdensome to the Service. in the alternative, they should be protected under the similarity of appearance provisions of the ESA.
2. Critical habitat must be designated. Given that there is little trade in the species, it is hard to imagine poaching being problem, particularly if the trade specimens are left out of the rule. Moreover, we know what the PCEs are for this species--it starts with discrete areas with serpentine soils/greenstone, including Mt. Davidson. These areas should be designated as unoccupied critical habitat.
3. Protection of critical habitat will have enormous benefits for this species in particular, because there is only one individual left in the wild. protecting unoccupied critical habitats, even off federal lands, will therefore be essential to the recovery program--by designating areas that are future reintroduction sites as critical habitat we ensure that recovery objectives will have the highest probability of success. Existing areas that contain Franciscan manzanita should also be designated. For example, a yard on Florida St. in the mission has a planted Franciscan manzanita from the Yerba Buena Nursery stock. The homeowners would welcome designation of this areas as critical habitat.
For the forgoing reasons, designating critical habitat is both prudent and determinable. The PCEs for the species have been identified during the relocation and through recent studies at SFSU. There are no known economic impacts of designating these areas as critical habitat. Therefore, occupied and unoccupied areas should be so designated.
Comment on FR Doc # 2011-22990
This is comment on Proposed Rule
Endangered and Threatened Wildlife and Plants: 12-Month Petition Finding and Proposed Listing of Arctostaphylos franciscana as Endangered
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