Comment from Katherine Kim, No Organization

To whom it may concern, I appreciate the opportunity to comment on the Critical Habitat for the Endangered Distinct Population Segment of Smalltooth Sawfish rule, a proposal to issue a protected area of land for the repopulation of juvenile sawfish. The following letter will comment on the benefits to biodiversity that the sawfish provides and the other positive externalities that can be extracted from this rule such as the public awareness. I believe that the proposed critical habitat is rightly presented. The endangered smalltooth sawfish needs a specific habitat that nurtures both the growth and the proliferation of the species. It has been on the endangered species list since 2001 and has lack a critical habitat. As a result, I support the adoption of this rule. Benefits to Biodiversity i. Smalltooth Sawfish The smalltooth sawfish has limited commercial and recreational value but they offer a greater benefit to biodiversity. As a mid-tier estuarine animal, its living conditions are fairly specific. So it would be difficult to find a replacement in the energy cycle that can fully fulfill the smalltooth sawfish’s role. By protecting the nursery grounds of the juvenile sawfish, we can more effectively ensure the growth of the population. ii. Habitat Protection Other benefits are expected accrue to society in the course of protecting the essential features of the sawfish’s critical habitat from destruction. Shallow waters with varying salinity levels offer a unique ecosystem for many species and it is one of the essential features of the critical habitats that are proposed to be protected. The shallow water euryhaline habitats offer ecosystem services to various juvenile fish, invertebrates, and benthic and epibenthic organisms. By protecting the habitat, the rule would protect against dredging projects that are often viewed as more pertinent than preserving a Floridian natural resource. a. Red Mangroves The red mangrove, as a primary producer, is the basic source of energy. It sustains the animals and plants in Florida. The litter that decomposes into the shallow waters is utilized by the microbial community. These species are, in turn, consumed by a larger number of higher consumers. In addition to contributing heavily to the carbon cycle and to increasing the detritus that is readily available, red mangroves provide habitat. It is the breeding grounds for many birds, mammals and reptiles. By protecting the critical habitat for the smalltooth sawfish, it is protecting many other species by reducing the rate of habitat destruction (which is one of the leading cause of species reduction). Other Benefits That May Result from the Critical Habitat i. Public Awareness and Education The history of the preservation of the Smalltooth Sawfish is originally rooted in community involvement. Much of the recorded sightings of sawfish were due to voluntary reporting. This proposed rule being created in the spirit of the history focuses on the preservation of the habitat and engaging the community. There are many positive externalities to this rule in addition to creating a critical habitat. The potential in this rule exist in being able to alter the activities of the community surrounding to benefit the ecosystem. This proposed rule engages the public to learn about the critical habitat for long term changes, not a short term quick fix. For this rule to be implemented, the efforts of the general public can be much more expansive. More responsibility would be given to the citizen to reduce mangrove trimmings or to engage in non-destructive recreational activities. ii. Overlap of Critical Habitats with the American Crocodile Currently the critical habitats for the American crocodile overlap with the proposed critical habitat for the smalltooth sawfish. Since both the American crocodile and the smalltooth sawfish utilize the mangrove swamps for nesting and foraging, it’s even more urgent to put more laws on preventative measures of the destruction of this habitat. Since the existing critical habitat designation for the American crocodile provides protection for the smalltooth sawfish, there is already an infrastructure in place for species protection. Conclusion In summary, I believe that the material proposed by the National Marine Fisheries Service (NMFS) is well-needed. I strongly urge the NMFS to maintain both the Charlotte Bay Harbor and the Everglades unit as the critical habitat. However, further clarification of the overlapping jurisdiction between the critical habitats of the American crocodile and the proposed critical habitat for the smalltooth sawfish would be beneficial. Clarification of how the two species protection agencies will deal with the overlap of jurisdictions. I appreciate the opportunity to share my views about the proposed critical habitat. Please feel free to contact me at 206-356-1478 or kkim@macalester.edu with any questions or to discuss further comments. Respectfully submitted, Katherine Kim