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Y <br /> projects, but would only serve to add time and cost to the project, and thereby act as a <br /> disincentive for the City of Eugene to implement the habitat management work that we feel we <br /> have done, and can do, better than any other organization in the Willamette Valley. <br /> C. Specific recommendations to USFWS <br /> The remaining areas proposed as critical habitat are occupied by one or more of the three <br /> species. To maintain and improve habitat quality, these areas need regular disturbance to <br /> maintain the plant community structure, as well as constant treatment to prevent invasive species <br /> from detrimentally affecting populations. Necessary management actions and their effects were <br /> outlined in the recently released (December 8, 2005) Biological Opinion (BO) and Letter of <br /> Concurrence on Effects of Implementation of the Ten-year schedule of Management Activities to <br /> Maintain, Enhance, and Expand Prairie Habitats within West Eugene Wetlands, FY 2006 -2016, <br /> on Fender's blue butterfly, Kincaid's lupine, Willamette Daisy, and Bradshaw's lomatium, <br /> Suislaw Resource Area, Eugene District, Bureau of Land Management (FWS Reference Number <br /> 1- 7 -06 -F- 0038). Treatments documented as necessary for habitat maintenance (pages 8 and 9 of <br /> the BO) include mowing, manual weed removal, prescription burning, the application of shade <br /> cloth, weed whacking, solarization, the use of chainsaws, and seeding. Therefore, it is essential <br /> that we be able to use these management tools within the areas designated as critical habitat and <br /> expect the designation of habitat as critical will make it easier for us to use these tools <br /> responsibly, instead of more difficult. <br /> As the USFWS acknowledged in the recent BO, there are many actions and tools necessary to <br /> restore and maintain prairie habitats. We hope that the designation of habitat as critical will <br /> assist us rather than constrain or impede our ability to manage land. We support the critical <br /> habitat proposal to the extent that it will help us manage the land consistent with rare species <br /> needs, but not if it is going to make it more difficult us to manage land for the benefit of these <br /> species. <br /> To ensure that management actions that will benefit these species are implemented without <br /> unnecessary regulations (that will only lead to delays and increased cost in implementing <br /> habitat management actions consistent with these species protection and recovery), we <br /> recommend adding language to the final critical habitat designation that states the <br /> following: <br /> 1. There will be no need for additional Section 7 consultation on the West Eugene Wetlands <br /> Schedule Environmental Assessment No OR090- EA- 05 -03, dated November 4, 2005, and <br /> its associated Biological Opinion (BO) and Letter of Concurrence on Effects of <br /> Implementation of the Ten-year schedule of Management Activities to Maintain, Enhance, <br /> and Expand Prairie Habitats within West Eugene Wetlands, FY 2006 -2016, on Fender's <br /> blue butterfly, Kincaid's lupine, Willamette Daisy, and Bradshaw's lomatium, Suislaw <br /> Resource Area Eugene District, Bureau of Land Management (FWS Reference Number 1- <br /> 7-06-F- 0038), dated December 8, 2005. <br /> 2. There will be no need for Section 7 consultation or other USFWS review on any City of <br /> Eugene owned lands identified as proposed critical habitat that currently do not contain any <br /> of the three species. As mentioned before, portions of Units FBB -10B and FBB -11 D (which <br /> Page 4 <br />