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2013-05-07_PERMIT FILE - M2013007
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2013-05-07_PERMIT FILE - M2013007
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Last modified
8/24/2016 5:20:16 PM
Creation date
5/9/2013 7:46:44 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M2013007
IBM Index Class Name
PERMIT FILE
Doc Date
5/7/2013
Doc Name
Response Items to Protest Letters
From
Greg Lewicki And Associates, PLLC
To
DRMS
Email Name
WHE
Media Type
D
Archive
No
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This letter provides a concise overview of our perspective on the proposal; our detailed <br />comments are enclosed. <br />Science <br />We respectfully submit that the science -based arguments in the rules have many <br />weaknesses. Some information in the proposed rules is misinterpreted or misquoted and <br />some important published work that is contrary to the proposed rules appears to have <br />been omitted from the proposals. We note several instances where the proposals cite <br />subjective or speculative statements from the literature that are not supported by data. <br />The enclosure addresses our concerns in greater detail. <br />Population Sizes and Trends <br />Available data on the status of the Gunnison Basin population of GuSG demonstrate that <br />this population is relatively stable. In fact, recent lek counts in the Gunnison basin are at <br />historic highs. Furthermore, lek counts in about half of the small outlying populations in <br />Colorado have increased in recent years; the increased numbers of males on leks is <br />encouraging and may be tied to our efforts to augment these populations and movements <br />of birds. We advocate for continued aggressive conservation measures directed at these <br />populations. Three independent Population Viability Analyses (PVAs) consistently <br />conclude that the Gunnison Basin population is at little risk of extinction. The PVA <br />included in the Rangewide Conservation Plan (GSRCP 2005) suggests that the <br />probability of extinction in the Basin is <1% in the next 50 years and that projection was <br />made at a time (2005) when the Basin population was significantly (approximately one <br />third) smaller than it is today. <br />Threats to the Gunnison Basin Population <br />Sixty -seven percent (67 %) of GuSG habitat in the Basin is owned by the federal <br />government (and therefore should be managed in a way that conserves GuSG), 31 % is in <br />private ownership and 2% is owned by the state. In our opinion, at least 79% of the <br />occupied range within the basin is adequately protected from threats such as <br />development (e.g., via federal management, conservation easements, CCAA certificates <br />of inclusion, county land use regulations) (enclosure, Table 1). <br />Production areas, defined as habitat within 4 miles of a lek, are arguably the most <br />important component of occupied habitat. In the Gunnison Basin, 81% of nests and 80% <br />of seasonal habitat occurs within 4 miles of a lek; 82% of this production area habitat <br />has some level ofprotection (enclosure, Figure 4). <br />We believe that the federal listing proposal overstates the threat of development by <br />basing projection on a short and anomalous period of time and inappropriately bases it on <br />demand for amenities near the Crested Butte ski area, which is not applicable outside of <br />the East Fork Valley. More appropriate data are available from Colorado Department of <br />Local Affairs (DOLA) (enclosure, page 6). In addition, Gunnison County has undertaken <br />
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