On Designating Critical Habitat (A Public Comment)

*Note: This note was submitted as a public comment to the Federal Register in response to a proposed rule by the Fish and Wildlife Service and the National Oceanic and Atmospheric Administration on July 31st, 2018. (Docket ID: FWS-HQ-ES-2018–0006)*

To Whom It May Concern:

I would like to voice my concerns regarding the proposed revisions to criteria used to designate critical habitat for threatened and endangered species. The agencies propose in section 424.12(a)(1)(ii) that if a species is not primarily threatened by modification or loss of habitat, then designating habitat as critical for that species may not be prudent. In their reasoning for this proposed change, the agencies argue that designating critical habitat for species not experiencing habitat-related threats would do nothing to address the actual threats a species is facing. Such an effort therefore does not “serve its intended function to conserve the species.” This reasoning is directly at odds with research that illustrates the importance of maintaining high-quality habitat for species not immediately threatened by modification or loss of current habitat, but threatened instead by other aspects of global change, such as the spread of invasive species or infectious disease, rising temperatures, weather extremes, or (to use examples provided by the agencies) loss of snowpack, glacial melt, and sea level rise.

Firstly, many of these stressors do contribute to loss of suitable habitat. For example, invasion of non-native aquatic species, such as zebra mussels, in Wyoming is threatening the state’s fisheries (Wyoming Game and Fish Department 2010) and sea level rise is inundating intertidal zones that provide crucial habitat for seabirds (Galbraith et al. 2002). I do not believe it is appropriate to consider the effects of global environmental change on the availability of suitable habitat as separate from the effects of land use change (e.g. urbanization, industrialization). Either way, threatened and endangered species are losing habitat that is critical to their recovery and worth designating as such. Furthermore, protecting critical habitat ensures that it will not be used for activities that could lead to habitat loss or worsen other threats in the near future.

Secondly, drivers of extinction are often synergistic; multiple stressors may lead to rapid population declines (Brook et al. 2008). For example, the abundance of eastern oysters in the Chesapeake Bay has rapidly declined since 1980 due to overexploitation, loss of habitat, and disease (Wilberg et al. 2011). The Gunnison sage-grouse — found in southwestern Colorado and southeastern Utah — is threatened by loss of habitat, ongoing recreational and tourism activity, and droughts (Storch 2007). Therefore, if the goal of these agencies is to ensure that conservation efforts are “effective” and “efficient,” it is necessary that they to work toward mitigating a multitude of threats simultaneously rather than focusing on what is determined to be the primary extinction driver for a given species.

Designating critical habitat is one of the most powerful tools the agencies have in protecting threatened and endangered species. All threatened species benefit from additional habitat protection, regardless of the primary extinction drivers in play. Critical habitat designation should be considered a key component of the management plan of any threatened or endangered species. The agencies are requesting public comment “to ensure these regulations are effective in furthering the ESA’s ultimate goal — recovery of our most imperiled species to the point they no longer need federal protection.” One of the most effective and efficient routes to recovery is habitat protection, and as such I oppose the proposed changes to section 424.

The sources for the research cited above can be found at the end of this comment. I hope the agencies will consider how recent research regarding the impact of multiple stressors on imperiled species underscores the ineffectiveness of this regulation in achieving its stated purpose.


Olivia V. Sanderfoot
National Science Foundation Graduate Research Fellow
School of Environmental & Forest Sciences, University of Washington

Master of Science (Environment & Resources), University of Wisconsin–Madison (2017)
Bachelor of Science (Majors: Biology, Spanish; Certificate: Environmental Studies), University of Wisconsin–Madison (2015)

Image for post
Image for post
Alpine meadow in Mount Rainier National Park. Alpine ecosystems around the world are threatened by rapidly rising temperatures, loss of snowpack, and glacial melt.


Brook et al. 2008. Synergies among extinction drivers under global change. Trends in Ecology and Evolution. 23(8): 453–460.

Galbraith et al. 2002. Global Climate Change and Sea Level Rise: Potential Losses of Intertidal Habitat for Shorebirds. Waterbirds: The International Journal of Waterbird Biology. 25(2): 173–183.

Storch 2007. Conservation status of grouse worldwide: an update. Wildl. Biol. 13 (Suppl. 1): 5–12.

Wilberg et al. 2011. Overfishing, disease, habitat loss, and potential extirpation of oysters in upper Chesapeake Bay. Marine Ecology Progress Series. 436: 131–144.

Wyoming Game and Fish Department. 2010. Wyoming Aquatic Invasive Species Management Plan.

Welcome to a place where words matter. On Medium, smart voices and original ideas take center stage - with no ads in sight. Watch
Follow all the topics you care about, and we’ll deliver the best stories for you to your homepage and inbox. Explore
Get unlimited access to the best stories on Medium — and support writers while you’re at it. Just $5/month. Upgrade

Get the Medium app

A button that says 'Download on the App Store', and if clicked it will lead you to the iOS App store
A button that says 'Get it on, Google Play', and if clicked it will lead you to the Google Play store