Transmitted via FAX -- 805 644 3958 - on 6-January-2002
ATTN: Lois Grunwald, US Fish and Wildlife Service
Comments on the Critical Habitat Designation for Chlorogalum purpureum
Attn: RIN-10180-AG75
Dear Sirs/Madames:
On behalf of the Ventana Wilderness Alliance (VWA) I am writing to express our strong support of the U.S Fish and Wildlife Service's (FWS) plans for designation of critical habitat for the two subspecies of Chlorogalum purpureum. As noted recently in the Federal Register, these rare plants inhabit and depend upon an extremely limited range of Central California's coast range foothills and certainly warrant the protective measures proposed.
Of particular concern to the VWA are the populations of Chlorogalum purpureum that exist on Fort Hunter Liggett (FHL) and Camp Roberts (CR). It has been our experience that the Army can be less than diligent about following the rules of NEPA as they apply to the protection of federally listed species. We urge you to begin formal section 7 consultation with the Army on the issue as soon as possible, and to plan for ongoing consultation to ensure appropriate management strategies for the designated critical habitat and the conservation of this rare subspecies. Furthermore, we urge you to arrange comprehensive and ongoing surveys of both FHL and CR in order to ascertain the full extent of present habitat range and thereby be able to afford the subspecies the fullest possible protection.
Lastly, the VWA is supportive of an open management strategy for the future: If the present habitat range for either subspecies is seen to enlarge or shift, it is essential that the FWS take appropriate action by reflecting the change in the designation and management of the critical habitat.
Respectfully,
Boon Hughey, Board Member
Ventana Wilderness Alliance
PO Box 506
Santa Cruz, CA 95061