Click to view RDC's Comment Letter

Deadline for comment is August 6, 2007

Overview:

The U.S. Fish and Wildlife Service (FWS) announced that a petition to list the Yellow-Billed Loon under the Endangered Species Act (ESA) might be justified. An ESA listing would lead to critical habitat designations posing far-reaching significant impacts to human activities in Alaska from the National Petroleum Reserve-Alaska (NPR-A) to the Southeast Panhandle with no added benefit to the species.

The Yellow-Billed Loon and its habitat are already protected by the Migratory Bird Treaty Act, in addition to the Conservation Agreement signed in 2006.  According to government surveys, the number of birds has not significantly declined; therefore listing the species may not have a beneficial effect on the population.  Oil and gas exploration and development, mining, and fisheries could be affected by this listing.

For additional information, refer to the Federal Register Notice located at:

http://edocket.access.gpo.gov/2007/pdf/E7-10823.pdf

Action Requested: 

RDC urges its members to submit comments opposing an ESA listing for the Yellow-Billed Loon.

Submit written comments to:

Online comments may be submitted at http://wwww.regulations.gov.

Faxes may be sent to (907) 456-0208.

Deadline for comment is August 6, 2007

Points to consider for your comments:

• Listing of the Yellow-Billed Loon under the Endangered Species Act could restrict and reduce responsible development of Alaska’s natural resources with no added benefit to the species.
• The Yellow-Billed Loon and its habitat are already protected by the Migratory Bird Treaty Act, in addition to the Conservation Agreement signed in 2006.
• If listed under the Endangered Species Act, 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.
• No indication of destruction or pollution of breeding grounds has been recorded in the National Petroleum Reserve – Alaska (NPR-A). Development is closely regulated and constantly monitored. 
• The proposed listing appears to be more about reducing and restricting resource development across Alaska, especially in NPR-A, rather than protecting the species. 
• 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.  An increase of over 25% in the number of nests in the area has been observed from 1983 to 2003.
• Yellow-Billed Loons nested in the Alpine area of NPR-A before construction, and the number nesting there during construction and operation of the oil field has not declined.

Deadline for comment is August 6, 2007