Resource Development Council

RDC Comment Letter:
Yellow-billed Loon Proposed ESA Listing Comments

August 6, 2007

Yellow Billed Loon Comments
Endangered Species Branch
Fairbanks Fish and Wildlife Field Office
U.S. Fish and Wildlife Service
101 12th Avenue, Room 110
Fairbanks, AK 99701

Re: Yellow-billed Loon

To Whom It May Concern:

The Resource Development Council (RDC) appreciates the opportunity to comment on the proposed Endangered Species Act listing of the Yellow-billed Loon.  RDC does not surmise the listing will be beneficial to the bird, and therefore, does not support the listing.

RDC is a statewide organization made up of all resource sectors, business associations, labor unions, Alaska Native corporations, tourism providers, local governments and individuals.  RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources. 

The Migratory Bird Treaty Act, in addition to a Conservation Agreement signed in 2006, protects the yellow-billed loon.  The established strategies and stipulations therein, provide extensive regulation to promote protection of the yellow-billed loon and its natural habitat.  

The 2006 Conservation Agreement provides a wide range of protection for the yellow-billed loon’s habitat, including breeding grounds.  An ESA listing in addition to the Conservation Agreement would not further benefit the loon, and would only discourage further investment in Alaska. If listed under the ESA, Section 7 ESA consultations will be required for any project found within the range of the yellow-billed loon.  This added cost, time, and the increased potential for litigation may discourage investment.

Exploration and development activities in the yellow-billed loon’s habitat are closely regulated and constantly monitored.  Indication of destruction and pollution of breeding grounds has not been recorded in the National Petroleum Reserve – Alaska (NPR-A).  In addition, yellow-billed loons nested in the Alpine area of NPR-A before construction in 1998, and the number nesting there during construction and operation of the oil field has not declined.  Further, aerial surveys of the Colville River Delta have indicated an increase in the number of nests in the area, despite 40 years of oil and gas exploration and development.  The increase of over 25% in the number of nests in the area was observed from 1983 to 2003.

Additionally, the yellow-billed loons breeding in Alaska do not warrant a distinct population segment.  In 2002 and 2003, all 11 of the loons outfitted with transmitters were found to winter off Asia, some as far as the Yellow Sea.

In conclusion, given the protections already established for the yellow-billed loon under the 2006 Conservation Agreement and the Migratory Bird Treaty Act, the proposed listing under the ESA is not warranted at this time.

Thank you for the opportunity to comment on the proposed rule.


Resource Development Council for Alaska, Inc.