Comment on FR Doc # 2012-06221

This is good policy. Anything that avoids the regulatory burden of the ESA should be implemented, because there are numerous examples of species whose decline has been accelerated by listing, simply due to landowner fears of having a listed species on their property. The direction that the Service has taken with the Sage-grouse here in the West was appropriate, and it was good to see that the Sage-grouse Initiative developed with NRCS. Although another subsidy to landowners, it has at least slowed down some of the destructive land-use practices in the region. My reccomendations: 1) The Service should expand the Partners for F&W program, hiring more competent and motivated field biologist to provide the necessary conservation assistance. They should be housed in NRCS offices and focus on priority habitats rather than specific species. 2) The Service should seek the guidance of State Fish and Wildlife agencies more often. Providing additional capacity at the State level is essential to eliminate the need for Federal management. Federal management should be a last-resort option to save a species. State Wildlife Grants for nongame species should be increased. 3) Do not hire any more bureaucrats. Provide funding for on-the-ground biologists, who get out of the office on a regular basis. 4) Work with counties to build the capacity for habitat conservation planning. The Feds could provided additional funding to counties that are willing to develop land-use regulations that ensure critical habitats are set aside.