Critical Habitat for the SW Alaska Sea Otter DPSFebruary 17, 2009 (Submitted Online) The Resource Development Council for Alaska (RDC) appreciates the opportunity to submit comments on the proposed Critical Habitat designation for the Southwest Alaska Distinct Population Segment of the northern sea otter. RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources. Subsection (5)(C) of Section 3 of the Endangered Species Act of 1973 (ESA) states “. . . critical habitat shall not include the entire geographical areas which can be occupied by the threatened or endangered species.” We feel 15,000 square kilometers is excessive and the proposed critical habitat areas should be significantly decreased. Sea otters have long lived in conjunction with fishing, transportation, oil & gas development, and other related activities. Indeed the most likely cause of decline of this stock of sea otters is through orca predation. As was demonstrated through the recent stellar sea lion example, the impacts to the economy and the welfare of the people living in the affected areas through the designation of such excessive critical habitat could be extreme. The ESA specifically allows for areas to be excluded from critical habitat for economic reasons. Subsection (2) of Section 4 of the ESA, “The Secretary may exclude any area from critical habitat if he determines that the benefits of such exclusion outweigh the benefits of specifying such area as part of the critical habitat, unless he determines, based on the best scientific and commercial data available, that the failure to designate such area as critical habitat will result in the extinction of the species concerned.” In specific, RDC requests the Secretary exclude the following areas of proposed critical habitat from the final rule for economic considerations, as doing so will not lead to the extinction of this stock of sea otters:
Thank you for the opportunity to comment on this important issue. Sincerely, |