This proposed rule designating critical habitats for salmon should be promulgated. Its aim is to learn more about the delicate habitats necessary for threatened Coho and Steelhead populations to survive. Any negative effect of this study would be negligible and outweighed by the benefits of preventing the extinction of these species of salmon.
There is not much of a downside to allowing NMFS to learn more about these habitats. This rule does not seek to regulate activities of businesses or citizens around such critical habitats, but merely designates which areas are imperative for salmon to continue to spawn and survive. However, businesses surrounding the Columbia River or Puget Sound could have reservations about this rule because once these critical habitats have been documented, it may pave the way for regulations that will affect how they can conduct business in the future -- whether their businesses are allowed to emit chemicals into the water, obstruct waterways, or develop non-urbanized land.
On the other hand, there are many benefits to this rule. It is clear that based on the complicated spawning and migratory habits of salmon, especially as it greatly differs between different species, learning more about the conditions that make it possible for salmon to survive will help society protect these areas into the future. There is little argument that learning more about what endangered species need to survive would be negative. Also, Steelhead and Coho salmon are currently on the "Threatened Species" list, which means that we have a limited time to act before the environment has been irreparably damaged and these species become extinct.
Any argument that economic concerns outweigh the need for this designation of critical habitats would be premature, as this rule does not call for specific action. If anything, this rule should be promulgated to ensure that future regulations regarding salmon habitats are as informed and effective as possible.
Comment from Kathleen Manning
This is comment on Notice
Endangered and Threatened Species: Designation of Critical Habitat for Threatened Lower Columbia River Coho Salmon and Puget Sound Steelhead
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