Comment from Lopez, Leigh Ann

I respectfully submit this comment as a Master of Public Health student at the University of Hawaiʻi at Mānoa who was born and raised in Hawaiʻi. Growing up in an island community has shaped my understanding of the close relationship between land, water, culture, and community well-being. For island communities, environmental decisions often have impacts that extend beyond ecology alone and affect food systems, cultural practice, mobility, and long-term resilience. I support the Fish and Wildlife Service’s goal of protecting endangered and threatened species through the proposed designation of critical habitat for 22 species in Guam and the Commonwealth of the Northern Mariana Islands (CNMI). However, I urge the agency to strengthen the final rule through several improvements that would make implementation more equitable, durable, and effective. First, the Service should adopt a stronger early-engagement framework with Indigenous and local communities before finalizing habitat boundaries or management approaches. Public comment periods are important, but they should not be the first or only point of engagement. CHamoru and Carolinian (Refaluwasch) communities possess generations of ecological knowledge tied to specific landscapes, waters, and species. Meaningful consultation at the earliest stages of rulemaking would improve decision-making and build community trust. Second, the agency should consider establishing a co-management or shared stewardship framework for designated areas where feasible. Rather than relying solely on top-down federal administration, co-management agreements with territorial agencies, local leaders, and community organizations could better align conservation goals with local practices and needs. Collaborative stewardship models in other island contexts, including Hawaiʻi, have shown that Indigenous and community-led management can strengthen biodiversity outcomes while preserving cultural continuity. Kamelamela et al. (2022) describe how place-based stewardship systems can support both ecological restoration and community resilience. Third, the final rule should include clearer protections for continued cultural access and traditional subsistence practices that are compatible with species recovery. Many communities in Guam and the CNMI maintain strong ties to gathering areas, fishing grounds, and culturally significant landscapes (Mushynsky et al., 2022). The rule should explicitly clarify that conservation implementation will seek to avoid unnecessary disruption to lawful and sustainable cultural uses whenever consistent with the Endangered Species Act. Fourth, the Service should improve accessibility of outreach materials and participation opportunities. Because the proposal covers multiple islands with distinct communities, notices and educational materials should be available in accessible formats and relevant local languages where possible. Public meetings should be offered virtually and in-person at times convenient for working residents. Expanding participation opportunities would help ensure that comments reflect a broader range of affected voices. Fifth, the agency should commit to ongoing monitoring and adaptive management after designation. Climate change, invasive species, storm events, and changing land conditions can quickly alter island ecosystems. The final rule should include a clear process for periodic review, updated science, and continued stakeholder engagement so habitat management remains responsive over time. In conclusion, I support the conservation intent of this proposed rule. Protecting biodiversity in Guam and the CNMI is essential, but conservation policy should also respect the people whose identities, histories, and livelihoods are tied to these lands and waters. A final rule strengthened through early consultation, co-management opportunities, cultural access protections, accessible participation, and adaptive management will be more just, more effective, and more sustainable. Thank you for the opportunity to comment. Kamelamela, K. L., Springer, H. K., Ku’ulei Keakealani, R., Ching, M. U., Ticktin, T., Ohara, R. D., Parsons, E. W., Adkins, E. D., Francisco, K. S., & Giardina, C. (2022). Kōkua Aku, Kōkua Mai: An indigenous consensus-driven and place-based approach to community led dryland restoration and stewardship. Forest Ecology and Management, 506, 119949. https://doi.org/10.1016/j.foreco.2021.119949 Mushynsky, J., McKinnon, J., Cabrera, G., & Tudela, H. (2022). The foundation of Island Identity: Chamorro maritime practices and resistance in the Commonwealth of the Northern Mariana Islands. AlterNative: An International Journal of Indigenous Peoples, 18(2), 299–312. https://doi.org/10.1177/11771801221084123