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projections of development in the county and is an excellent source of accurate data on <br />historic growth patterns. <br />We believe the Fish and Wildlife Service (FWS) significantly overstates the threat <br />represented by roads, powerlines, fences and grazing. The proposed rule is based on a <br />2012 National Park Service study of impacts of roads that is not representative of the <br />Gunnison Basin as a whole; we present compelling data from throughout the Basin that <br />refutes the NPS study (beginning on page 6 of the enclosure and also see Figure 3). The <br />listing proposal treats correlative studies on powerline impacts as conclusive, despite no <br />demonstrated cause and effect relationship. CPW has telemetry data that contradict FWS <br />statements made about fragmentation of habitat and the impact (or lack thereof) of fences <br />on sage- grouse mortality rates. Although admitting that no studies have linked livestock <br />grazing practices to grouse population levels, the FWS proposal concludes that grazing, <br />in conjunction with climate change, is a threat to sage - grouse, and dismisses CPW <br />monitoring data that indicate large portions of breeding habitat in the Gunnison Basin <br />meet or exceed GuSG habitat guidelines under existing grazing management. <br />Significant Portion of the Range <br />We conclude that the GuSG is adequately protected throughout a significant portion of its <br />range, and therefore does not warrant protection by listing under ESA. Our position is <br />based on information indicating that 88% of the entire species' population is contained <br />within the Gunnison Basin population and nearly 80% of the Basin population's habitat is <br />protected in some fashion from the habitat threats identified in the proposal (enclosure, <br />page 12). <br />The FWS has applied the concept of risk of extinction in a significant portion of range to <br />determine if a species as a whole is warranted for listing. Because the species is not <br />threatened with risk of extinction in such a significant portion of its range, we assert that <br />listing under ESA is not warranted for GuSG. <br />Historic Range and Critical Habitat <br />We believe FWS has overestimated the historic distribution of GuSG in the listing <br />proposal (enclosure, page 3). The historic distribution portrayed in the listing proposal <br />includes extensive landscapes that are non - habitat. When compared to the present -day <br />range, an inflated historic distribution results in an overstatement of the impact of habitat <br />loss and fragmentation. <br />We also believe there are serious deficiencies in the proposed critical habitat designation <br />(enclosure, page 18). One concern is the inclusion of vacant or unknown habitat and <br />potentially suitable habitat into the definition of critical habitat; much area designated as <br />potentially suitable habitat is lands that have soils unsuitable for supporting sage - brush, <br />and other lands will require extensive restoration to be suitable for GuSG as they have <br />become dominated by pinyon juniper or converted to rangeland. Given the lack of <br />