Comment from Pinque, Meryl

Dear U.S. Fish and Wildlife Service, I am writing in strong support of the proposed designation of critical habitat for 22 endangered and threatened species across Guam and the Commonwealth of the Northern Mariana Islands, as published in the Federal Register on March 24, 2026. I urge the Service to finalize and strengthen this rule without weakening or narrowing the proposed boundaries. The 22 species covered by this proposal — including the Pacific sheath-tailed bat, Slevin's skink, the Mariana eight-spot butterfly, the Mariana wandering butterfly, the Rota blue damselfly, four species of tree snails, and 13 rare plant species such as the Cycas micronesica — are found nowhere else on Earth. Many survive in extremely small, fragmented populations. For species in this situation, the protection of every remaining acre of suitable habitat is not merely beneficial — it is essential to prevent extinction. The proposed designation of approximately 59,886 acres across nine islands represents a meaningful step forward. However, I am deeply concerned about the proposed exclusion of more than 18,500 acres of military lands across Joint Region Marianas installations, including Andersen Air Force Base, Marine Corps Base Camp Blaz, and Naval Base Guam. Excluding these lands on the basis of Integrated Natural Resources Management Plans (INRMPs) is inadequate and repeats a pattern of failed promises. As documented by conservation organizations, a similar exclusion granted to the U.S. Navy in 2004 — based on commitments to protect habitat in what would become the Guam National Wildlife Refuge — resulted in the destruction of that very habitat during the construction of Camp Blaz. The last Mariana fruit bat colony on those lands has since disappeared. The Endangered Species Act is clear: exclusions are only lawful if the benefits of exclusion outweigh the benefits of designation, and only if exclusion will not cause extinction. Given the precarious status of many of the 22 listed species, and given the documented failure of military self-management to deliver meaningful conservation outcomes, I urge the Service to: 1. Include all military lands within the critical habitat designation where those lands contain physical or biological features essential to the conservation of listed species. 2. Reject reliance on unenforceable INRMPs as a substitute for the legal protections that critical habitat designation provides under Section 7 of the ESA. 3. Finalize the rule to encompass the full extent of habitat these species need to survive and recover. The Mariana Islands are facing an accelerating extinction crisis driven by invasive species, habitat loss, climate change, and development pressures associated with ongoing military expansion. The Service has a legal and moral obligation to act decisively. I urge you to finalize the strongest possible critical habitat rule for these irreplaceable species. Thank you for considering this comment. Meryl Pinque