Center for Biological Diversity




Center for Biological Diversity's Critical Habitat Comment Letter

Fish and Wildlife Service: Proposed Critical Habitat



Your letters are needed in support and expansion of a proposal by the U.S. Fish & Wildlife Service to protect over 12,060 acres of critical habitat for the endangered Riverside fairy shrimp.

The Riverside fairy shrimp was listed as an endangered species on 8-3-1993. Critical habitat will expand Endangered Species Act protections to important Riverside shrimp vernal pool habitat in Orange, Riverside, Los Angeles, Ventura, and San Diego counties.

Vernal pools are seasonal wetlands that fill with water during fall and winter rains. They are home to many plants and animals that in turn form a valuable part of the food chain for a wide array of animals, including birds of prey, shorebirds, migratory waterfowl, frogs, toads, salamanders and pollinating insects. Vernal pools have been destroyed and degraded by urban sprawl, agribusiness, offroad vehicles, livestock grazing, and wetland draining. Riverside shrimp habitat has been reduced to just 25 vernal pool complexes in coastal southern California.

A large portion of remaining southern California pools exist on Marine Corps bases at Miramar and Camp Pendleton. The marines have successfully lobbied for critical habitat exemptions for the Arroyo southwestern toad, California gnatcatcher, San Diego fairy shrimp and are now lobbying fr a similar exemption for the Riverside shrimp. While this battle is raging, the Fish & Wildlife Service plans to exempt state and private lands which are already involved in so called "habitat conservation plans." The plans are actually permits allowing developers to kill endangered species and destroy their habitat in return for inadequate, often already committed, mitigation lands. The Center opposes the exemption of both the Marine bases and developer parcels.

Please send a letter to the Service no later than March 30 covering the following points:

  • Support designation of critical habitat for the Riverside fairy shrimp.
  • Expand the proposal to include all Riverside shrimp vernal pool habitat included in the Service’s Recovery Plan for Vernal Pools of Southern California.
  • Expand the proposal to include all Riverside shrimp vernal pool habitat located within the boundaries of existing so called “Habitat Conservation Plans.”
  • Support designation of Riverside shrimp critical habitat on Marine Corps bases Camp Pendleton and Miramar.

Please send your letter to:

Mr. Ken Berg, Field Supervisor
Carlsbad Fish and Wildlife Office
U.S. Fish and Wildlife Service
2730 Loker Avenue West
Carlsbad CA 92008

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