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management plan that includes protection of the birds, this lake was excluded. <br />Certainly a program developed by a group including the Fish and Wildlife Service <br />and the three states and participants such as the district is adequate protection <br />without the undue regulation and restrictions that may come from critical habitat <br />designation. <br />Regarding the procedural issues surrounding this proposed designation, I <br />am appalled at the actions of the Fish and Wildlife Service. The Service has had <br />since 1985, when it listed the piping plover as threatened, to designate critical <br />habitat. At that time the Service, in my view, correctly found that it was not <br />appropriate to designate critical habitat, because of the transitory nature of the <br />birds' nesting requirements. Notwithstanding that original finding as a result of a <br />lawsuit, the Service has now, for the very reasons it found inappropriate in 1985, <br />proposed critical habitat designation. In June of 2001 the Service proposed this <br />designation, providing only an incomplete environmental analysis, not the least <br />omission of which was an economic analysis. This so- called economic analysis <br />dated November 2001, was released to the public December 28, 2001, with a <br />requirement that comments were due in 30 days. Clearly the Service had the time <br />after the court decision to compile the necessary data and complete the necessary <br />analyses in a timely manner to fulfill their obligations; and yet, the Service chose <br />not to release this document until they held it for over a month and then during a. <br />holiday week. Not only was it released when few people were available, but it <br />was to be provided to the public electronically over the Department of the <br />