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that occur within these habitats. We also believe our organizational commitment to protecting these habitats is unparalleled in the Willamette Valley. It is primarily because of the Partnership and our management efforts that substantial wetland prairie and upland prairie habitat (including 80 acres of proposed critical habitat) still exists near Eugene. B. Some specific concerns regarding City of Eugene and Partnership lands As a member of the Partnership, the City of Eugene manages or helps to manage approximately 80 acres of habitat proposed as critical for the three species. As mentioned before, we have managed these and other natural areas to promote the persistence and expansion of rare plant and animal populations. We appreciate the effort that you have put into identifying areas of critical habitat and generally agree the areas you have identified are the key areas for conservation action. However, we would hope that these designations would assist us, rather than constrain our ability to do the habitat management that we have already demonstrated we can do very effectively. Having managed wetland prairie and upland prairie for many years, the Partnership has learned a great deal about maintaining and restoring these habitats and populations. Restoration and management activities such as mowing, solarizing, prescription burning, applying herbicide to encroaching invasive species, seeding with a diverse suite of native prairie forbs and grasses, planting plugs and bare -root stock, and hand weeding are often necessary to restore, maintain, and enhance habitat. It is our hope that these activities, when used appropriately, will be encouraged within the proposed critical habitat areas and not be unnecessarily constrained or regulated by the designation. It is important to highlight that some areas proposed for designation, including all of the areas owned by City of Eugene (e.g., portions of Units FBB -10B and FBB -11D, known locally as Dragonfly Bend, The Boot, Amazon Creek channel banks, and Fern Ridge bike path banks) do not currently contain rare species. These specific sites will need intense treatment before they would ever be used by these rare species or before they would be suitable for the reintroduction of these species. For example, sections of Unit FBB -11D (mapped on page 66547) delineate the banks of Amazon Creek and the banks of the Fern Ridge multi -use path. These areas are currently very poor quality habitat. The banks are, for the most part, steep, have poor quality soil (it is either side - castings from the dredging of Amazon Creek, exposed subsoil, or gravel fill from the construction of the bike path), and are dominated by many non - native and invasive weed species. To create suitable habitat in these areas would require extensive site preparation (e.g., using herbicides to kill the existing vegetation), augmenting the current soil, and sowing and plugging them with native species. These areas would also need a significant amount of annual treatment (weeding and seeding) to maintain habitat quality after the original work is done to prevent weeds from degrading the habitat. The City of Eugene has existing plans to enhance and restore some of these areas, and a long -term goal to enhance most of these areas. We would hope that our demonstrated success over 14 years at managing these habitats and the three focal species would preclude us from being subject to any additional regulations as a result of the critical habitat designation. Almost all of our projects are planned and implemented by an interdisciplinary, interagency team. Project plans are extensively reviewed and permitted already. Any additional regulation or process would add no additional benefit to the Page 3