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o n l,J ~i 7 .... " Colorado Field Supervisor United States Fish and Wildlife Service July 21, 1997 Page 2 . Mouse population and range: The Mouse hibernates for seven months beginning in September and is nocturnal during its few months of activity. Therefore identifying the location and numbers of mice is difficult at best. Maps issued by the United States Fish and Wildlife Service ["Service'l purportedly designating Mouse and habitat location have significant, inexplicable gaps such as those between Longmont and Laramie where there is no significant change in habitat. A five year, intensive trapping program would provide a credible population and range identification for the Preble's meadow jumping mouse. Listing should be delayed, and lawful activities continued, until there is sufficient, reliable information on which to make a decision. . Relic population: There is some question whether the Mouse is a relic population which has existed in low density numbers for an extended period oftime. Recovery of a relic population is a misnomer, and perhaps protection of existing populations is all that is required, . Water flows: The Federal Register notice dated March 25, 1997 proposing listing of the Mouse contained several hypotheses regarding water development and operation and decline of the Mouse, The Service has failed to prove the nexus between water flows and the population numbers of the Mouse. Funher study needs to be conducted regarding the Mouse population and water development so any information and suppositions are scrutinized prior to the potential harsh impacts from listing, The Service must prove how water depletion is cOMected to the decline of the species prior to publishing unsubstantiated hypotheses regarding water and the purported decline of the Mouse. 2, If the Mouse is listed, it should be as ''warranted, but precluded", and allow the State of Colorado and local government entities to head up a recovery program. The listing proposal is incorrect in stating only the federal government can protect the species, In November of 1995. Colorado and the federal government signed a Memorandum of Understanding regarding candidate or declining species providing for flexible recovery management. The Y1emorandum is working well concerning the stabilization and recovery of the boreal toad, another species presumably heading for a threatened or endangered listing. Public and private' entities are in the process of contracting with the state to create natural areas to preserve and enhance toad habitat, There is no reason to believe this type of response which has worked so well for recovery of the boreal toad would not be equally effective in addressing [he needs of the Preble's meadow jumping mouse.