Submitted Electronically via eRulemaking Portal

Determination of critical habitat must include consideration of the economic and cultural ramifications of the habitat declaration BEFORE the critical habitat recommendation is made. The regulations state clearly that "(b) The Secretary shall make any determination required by paragraphs (c) and (d) of this section solely on the basis of the best available scientific and commercial information regarding a species' status, without reference to possible economic or other impacts of such determination". Clearly, a decision that incorporates the "best" commercial data must include a complete economic analysis equivalent to the scientific analysis used to prepare the declaration. This economic analysis AND the scientific rationale must both be included before habitat is declared and must be made available to the public for comment as part of the critical habitat declaration filing. In addition, I object to the concept that any Agency can make a critical habitat decision SOLELY on the basis of scientific and commercial information. Cultural information and a complete Cultural Impact Analysis, including a Section 106 consultation, must be undertaken before any critical habitat declaration is made. This Cultural Impact Analysis, along with the economic analysis, must be included in the information made available to the public at the time the declaration of critical habitat is made. In addition, the economic and cultural implications of the decision must be analyzed in the habitat declaration in comparison to the scientific rationale, and all points of view need to be considered on an equal basis. This approach will save the agencies an inordinate amount of time dealing with incomplete analyses and with public perceptions due a lack of visibility into the decision-making process.