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, � December 29, 2005 COPY EUGENE Parks and Kemper McMaster O Space Field Supervisor U.S. Fish and Wildlife Service a division of Public works 2600 SE 98th Ave., Suite 100 1820 Roosevelt Blvd. Portland, OR 97266 Eugene, Oregon 97402 ( 1)8824800 SUBJECT: Proposed Critical Habitat Designation for Fender's blue (541) 682 -4882 Fax butterfly, Kincaid's lupine, and Willamette daisy www.d.eugene.or.us/parks Dear Mr. McMaster, The intent of this letter is to articulate the City of Eugene's perspective on the "Proposed Critical Habitat Designation for Fender's blue butterfly, Kincaid's lupine, and Willamette daisy", which was published in the Federal Register on November 2, 2005 (Volume 70, Number 211, 50 CFR, Part 17, pages 66492- 66599). Below, I will: Parks and Open 1. Provide some background on the City of Eugene's 14 -year history of Space Planning acquiring and managing wetland prairie and upland prairie habitats, often with a specific goal of protecting and improving habitat for the three Parks Maintenance species that are the focus of the proposed critical habitat designation. 2. Express some specific concerns about the potential, negative Urban Forestry repercussions of proposed critical habitat designation on the City of Natural Resources Eugene and our partners in the West Eugene Wetlands Partnership (e.g., U.S. Bureau of Land Management and The Nature Conservancy), with regards to our ability to effectively manage our lands for the benefit of the three species and the habitats on which they depend. 3. Recommend some specific USFWS actions that will fulfill the intent of critical habitat designation while also allowing habitat management activities, which are vital to maintain the habitat, to continue without unnecessary USFWS review. A. Background on City of Eugene and West Eugene Wetlands Partnership's history with wetland prairie and upland prairie management The City of Eugene and its partners in the West Eugene Wetlands Partnership (Partnership) are among the most experienced entities managing wetland prairie and upland prairie habitats in the Willamette Valley. Since 1992, the City of Eugene and the Partnership have garnered numerous state and national recognitions for our model wetlands program that incorporates wetlands protection, land acquisition, wetlands restoration, stream restoration, community education, a youth program, floodplain protection, and hydrological and ecological connectivity. As recently as this year, the City of Eugene was EUGENE Page 1